Kitemill AWE System
Kitemill
Concession Application - Revised

NAWEP
Norwegian Airborne
Wind Energy Pilot

Concession application for an airborne wind energy plant at Lista Airport, Farsund Municipality

Applicant Kitemill AS
Location Lista Airport, Farsund
Date April 2026
Funded by the European Union
Kitemill AS · License Application NAWEP Revised v2.0 · April 2026

CONCESSION APPLICATION

NAWEP - Norwegian Airborne Wind Energy Pilot

Airborne Wind Energy Plant at Lista Airport, Farsund Municipality

Applicant: Kitemill AS (org. no. 992 943 718) Date: 28 April 2026 Version: 2.0 - Revised following NVE (Norwegian Water Resources and Energy Directorate) feedback of 18.03.2026 (ref. 202421870-10) NVE case number: To be assigned upon submission


TABLE OF CONTENTS

  1. Summary
  2. About the applicant and project
  3. Municipal anchoring and process
  4. Maps and delimitation
  5. Technical description
  6. Grid connection and electrical infrastructure
  7. Land use and plant components
  8. Biodiversity
  9. Birds and migratory birds
  10. Landscape and visual impacts
  11. Noise
  12. Shadow flicker
  13. Outdoor recreation and outfield use
  14. Cultural heritage and cultural environment
  15. Public health and living environment
  16. Co-use and coordination
  17. Natural hazards and safety
  18. Cumulative impact
  19. Zero alternative
  20. Mitigation measures and commitments
  21. Appendices

1. SUMMARY

1.1 Project description

Kitemill AS is applying for a license to establish NAWEP (Norwegian Airborne Wind Energy Pilot) - an R&D project for airborne wind energy (AWE) at Lista Airport in Farsund municipality.

Key figures: - Installed capacity (grid feed-in): 1.2 MW (12 production units of 100 kW each + 3 R&D units) - Expected annual production: approx. 4.2 GWh at mature operation (3,500 full-load hours) - Operating altitude: 150-500 metres above ground - Plan area: approx. 1.5 km² within the airport's existing industrial area - Project period: 2026-2031 (6 years: 2 years installation, 3 years operation, phased)

1.1.1 Plan area and operating area - delimitation

In line with NVE's feedback, the distinction between the plan area and the operating area is clarified:

The plan area and operating area are therefore not identical. The operating altitude is described in section 4.6, and the airspace regime (danger area EN D257) in section 17.2.

1.2 Comparison with conventional wind power

Note: NVE's application template for wind power plants is designed for conventional turbines with permanent foundations and access roads. Airborne wind energy technology (AWE) has substantially different characteristics, and equivalent topics are addressed through descriptions of the ground station, service area, grid connection, operating pattern and operating restrictions in the relevant chapters.

Aspect Conventional wind power AWE (Airborne wind)
Height Fixed tower height (typically 80-150 m) Operating altitude 150-500 m
Foundation Large concrete foundations Light ground station on steel frame
Roads Requires access roads No new roads necessary
Visual impact Permanent, static Visible only during operation
Flexibility Fixed location Can be landed/removed quickly

1.3 Phased implementation

To uphold the precautionary principle (Norwegian Nature Diversity Act § 9), the project will be implemented gradually:

Year Activity Systems
2026 Test flying of R&D units, daytime only, monitoring programme established 1-3 (R&D)
2027 Installation of stations M, N, O under observation 3
2028 Installation of stations A-L, grid connection, commissioning 15
2029 Operating year 1 - full operation 15
2030 Operating year 2 - continued operation and optimisation 15
2031 Operating year 3 - termination and final evaluation 15

1.4 Non-technical summary of the environmental impact assessment

In accordance with the EIA Regulations (Norwegian Environmental Impact Assessment Regulations) § 17, a brief non-technical summary of the environmental impact assessment is provided here. The full impact assessment is enclosed (Appendix 07).

Purpose of the project: To establish NAWEP as a pilot and demonstration plant for airborne wind energy (AWE) at Lista Airport. The primary purpose is knowledge building about the technology, not large-scale power production.

Impacts on the environment and society:

Comparison with the zero alternative: Against the zero alternative (no development), NAWEP delivers +4.2 GWh/year of renewable energy (equivalent to approx. 270 households), +630 t CO2e/year of climate savings, 76-85 MNOK in direct regional investment and secured EUR 3.35M+ in EU funding (Innovation Fund, Horizon Europe, MSCA, HaDEA), against a permanent land use of only 0.05 hectares (520 m²) — fully reversible at project end. Industrial-scale impact: NAWEP is the precursor to Kitemill's FJORD factory (EUR 35M EU IF Clean Tech Manufacturing application, submitted 23.04.2026), which at mature operation provides 1,330 FTE and 176 MW annual production capacity, with Lista as a candidate location and a Norwegian supplier sector for winches, composites, tethers and power electronics. See section 19.4 for the full quantitative balance of benefits and drawbacks.

Mitigation measures: Gradual ramp-up, operational shutdowns during migration periods, continuous monitoring, measurement programmes for noise and birds, automatic flight termination with return-to-home, and documented reporting to authorities. See chapter 20.

Uncertainty: The knowledge base for AWE under Norwegian conditions is limited. The principal purpose of NAWEP is to build this base. All assessments reflect the precautionary principle, and the project may be adjusted or terminated if consequences are unacceptable.

1.5 Strategic significance

Airborne wind energy technology (AWE) represents a new approach to wind power production in which a wing profile operates in higher air layers (200-500 m) with access to stronger and more consistent wind resources than conventional turbines. The technology is still immature and under active international development, but efforts are under way through, among others, IEA Wind Task 48 and the EU's Horizon Europe programme to bring it towards commercial maturity.

International context. AWE is recognised as an emerging technology within several European and international frameworks:

National context. The Norwegian Energy Commission's report "Mer av alt - raskere" (NOU 2023:3) points to the need for at least 40 TWh of new power production by 2030. DNV's analyses (2024, 2025) indicate that Norway may become a net importer of electrical power in the early 2030s, with demand growth exceeding new development. At the same time, the development of conventional onshore wind power has met significant challenges related to land use, environmental interventions and local opposition. AWE technology has the potential to contribute to power production with substantially lower land requirements and material consumption than conventional alternatives, but this requires further technology development and documentation through projects such as NAWEP.

Potential of the technology at maturity. Although the technology is currently at an early stage, the fundamental physical and system characteristics suggest that mature AWE technology can offer substantial advantages compared with conventional wind power:

These properties are based on the system's physical operating principle and the company's calculations, and will be verified through the NAWEP project.

From complementary to primary alternative. In the maturation phase, where NAWEP is positioned, AWE is a natural complement to established renewable technologies. At technological maturity, however, AWE can evolve into a primary alternative that directly addresses the principal bottlenecks in deployment of conventional wind power in Norway:

NAWEP is the technical maturation platform that enables this transition. The timeframe for when AWE in Norway can move from complement to primary alternative depends on technological maturation, regulatory framework and industrial scale-up (cf. sections 19.4.5 and 19.4.6).

FACT BOX: NAWEP in brief

  • Applicant: Kitemill AS (org. no. 992 943 718)
  • Location: Lista Airport, Farsund municipality
  • Technology: Airborne Wind Energy (AWE) - airborne wind power plant
  • Capacity: 1.2 MW installed (15 x 100 kW systems)
  • Annual production: 4.2 GWh at mature operation
  • Plan area: approx. 1.5 km² within the airport's industrial area
  • Permanent land take: approx. 520 m²
  • Project period: 2026-2031
  • Purpose: R&D and knowledge building for airborne wind technology

2. ABOUT THE APPLICANT AND PROJECT

2.1 Applicant

Kitemill AS Org. no.: 992 943 718 Address: Flyplassveien 40, 4560 Vanse Contact person: Thomas Hårklau, CEO E-mail: th@kitemill.com

2.1.1 Ownership and corporate form

Kitemill AS is a Norwegian limited company with organisation number 992 943 718.

Major shareholders as of 12.09.2025:

Shareholder Registered shares Fully diluted*
Ignatia AS 33.6% 30.3%
En-Vision Europe Ltd 16.2% 14.8%
Andre Polderman (3 subscription tranches) - 8.1%
Bjørkehagen AS 5.1% 4.6%
Nanna Gjerde Invest AS 4.7% 4.2%
Kongsberg Innovasjon AS 3.9% 3.5%
Nannok Invest AS 3.4% 3.0%
Other shareholders (dispersed) 33.1% 31.5%

*Fully diluted includes Funding Round 1, stock options and outstanding warrants.

Board of Directors: - Jérôme Guillet (Chair) - Åslaug Marie Haga - Jon Gjerde - Svein Olav Torø

Management: - Thomas Hårklau - CEO - Marius Dyrset - CTO - Asgeir Lønø - CFO

Group structure: Kitemill AS has two wholly owned subsidiaries that function as special purpose vehicles (SPV) without employees: - NAWEP AS - SPV for the airborne wind power project at Lista (the subject of this concession application) - Exact Aircraft AS - SPV

The company has no parent company.

2.2 Background

Kitemill AS is a Norwegian technology company founded in 2008, with R&D headquarters at Lista Airport. The company develops airborne wind energy technology (AWE) which exploits stronger and more consistent winds at higher altitudes.

2.3 Project objectives

NAWEP is primarily a research and development (R&D) project with the following main objectives:

  1. Demonstrate AWE technology under Norwegian climatic and regulatory conditions
  2. Document and assess environmental impact, with particular emphasis on birds and migratory birds
  3. Develop operating protocols for coexistence between AWE operation and natural values
  4. Establish a knowledge base for future commercial roll-out of the technology
  5. Contribute to increased knowledge of birds and migratory birds at Lista, including spring migration and AWE-specific bird behaviour

Knowledge building: The applicant has the stated goal of contributing to knowledge building both before and throughout the project period. This entails systematic collection and sharing of data on bird activity, the technology's impact and the effect of mitigation measures. All collected knowledge will be shared with relevant authorities and contribute to the overall knowledge base for AWE technology in Norway.

The project is co-financed by the EU, reflecting the project's relevance within the EU's framework for energy transition.

2.4 Societal benefits

2.4.1 Regional energy situation

Southern Norway (price area NO2) has in recent years experienced the highest electricity prices in the country. In December 2024, the spot price in NO2 reached NOK 13.16/kWh (Nord Pool), among the highest registered for the price area, and throughout 2025 prices in southern price areas have been many times higher than in Northern Norway. The cause is limited transmission capacity between north and south, combined with export through interconnectors.

Any new local power production in the region contributes directly to strengthening security of supply and dampening price pressure. The NAWEP project, with its 1.2 MW installed capacity and expected annual production of up to 4.2 GWh at mature operation, will provide a limited but real contribution to regional power production. The project's primary value in this context is, however, the knowledge it generates regarding AWE technology's suitability for large-scale roll-out in the region.

The production profile of AWE technology has properties relevant to security of supply. The figure below shows the monthly capacity factor for AWE compared with conventional wind power and solar energy, set against electricity consumption in Southern Norway. AWE achieves a higher capacity factor than conventional wind power throughout the year, and the production profile follows the consumption curve more closely than both solar and conventional wind. Solar energy has the highest capacity factor in summer when consumption is lowest, while AWE has the highest production in the winter half-year when consumption and prices are highest. This complementarity makes AWE technology relevant to security of supply in Southern Norway.

Figure: Monthly capacity factor for various renewable energy sources compared with electricity consumption in Southern Norway. AWE shows a higher and more even capacity factor than conventional wind power, and a production profile that better matches the consumption pattern.

2.4.2 Local value creation

The project entails direct local activity through:

2.4.3 Knowledge building and industrial development

Kitemill is among a limited number of active AWE developers globally that combine long-term field testing, regulatory engagement and participation in international research and coordination frameworks. The company participates in several EU-funded research and innovation projects and is an active participant in international AWE coordination through IEA Wind TCP Task 48. In contrast to many AWE initiatives that are primarily laboratory- or model-based, Kitemill's work is characterised by long-term outdoor operation, licensing processes and engagement with grid, aviation and environmental authorities. This gives Kitemill a relevant role as a reference for applied and deployment-oriented AWE development, complementing more academically oriented initiatives within the field.

The project contributes to knowledge building at several levels:

2.4.4 European and global context

The EU Innovation Fund has awarded the project EUR 3.35 million, reflecting an assessment of the project's relevance for European energy transition. The EU's climate framework (Fit for 55, RED III) sets a target of at least 42.5% renewable energy by 2030, and the EU needs an estimated 510 GW of wind power capacity to achieve this target. AWE technology can in time complement conventional wind power, particularly in areas where traditional development encounters land-use constraints.

Norway's climate commitments (55% reduction by 2030, 70-75% by 2035) require a significant increase in renewable power production. NAWEP contributes to developing a technological alternative that, at maturity, can make a substantial contribution to this transition.

2.4.5 Societal benefit and technology maturation

NAWEP represents a technology maturation project with a broader societal perspective than pure energy production. Kitemill's early-phase systems have commercial applications beyond power production, contributing to the maturation and financing of the technology towards its ultimate role as a large-scale renewable source.

Civil emergency preparedness and services: - Protection of critical infrastructure through continuous airspace presence (ISR - Intelligence, Surveillance, Reconnaissance) - Monitoring of environmental emissions, including emissions from ports, industry and transport - Monitoring and early warning of forest fires and other natural events - Support to rescue services through persistent monitoring during incidents - Communications support in areas with poor coverage

Portable renewable energy: AWE differs fundamentally from conventional wind and solar power in that the production plant can be moved. A KM2 plant produces annual energy equivalent to 12-15 truckloads of diesel. This opens up applications that are not possible with ground-fixed renewable solutions:

Technology maturation pathway: These applications represent important maturation steps that gradually qualify airborne wind technology. Each application contributes to additional flight hours and a larger data base, further development of control algorithms and safety functions, cost reduction through volume effects, and the establishment of regulatory pathways for AWE.

Energy as a long-term goal: Once the technology is qualified through commercial early-phase applications, it will be deployable at large scale as renewable energy production at sites where conventional wind power is not feasible or desirable. This may contribute substantially to Norway and the EU recovering ground towards their net-zero ambitions, with airborne wind as a complement to ground-mounted wind power and solar energy. The NAWEP project at Lista is therefore not only a power development project, but a strategic technology development measure with significant societal benefit throughout the qualification phase.


3. MUNICIPAL ANCHORING AND PROCESS

3.1 Contact person at Farsund Municipality

See Appendix 33: Contact persons and stakeholders (EXEMPT FROM PUBLIC ACCESS)

The municipality's case officer for Kitemill's original dispensation application in 2018 has knowledge of the project from an early stage.

3.2 Dialogue and start-up meetings

Kitemill has had ongoing dialogue with Farsund municipality since 2017. Key milestones are summarised below:

Date Meeting/Event Participants Decision/Conclusion
12.12.2017 Application for temporary test plant Kitemill AS Submitted to the municipality
22.03.2018 Technical Committee, case 18/41 Thomas Hårklau briefed Unanimously approved with conditions on bird monitoring
Feb 2025 Invitation to dialogue meeting v1 Kitemill, Farsund municipality NAWEP project presented
14.03.2025 Dialogue meeting Lista Airport Kitemill, Farsund Lufthavn AS Lease agreement discussed
28.03.2025 Application for temporary dispensation for demonstration plant Kitemill AS Submitted to the municipality
17.06.2025 Technical Committee, case 61/25 Jan Hornung briefed Unanimously adopted with conditions

3.3 Zoning plan and municipal decisions

Lista Airport is regulated through the Municipal sub-plan for Lista flight and business park.

Zoning purposes: - Airport (main purpose) - Industrial and business purposes - LNF (Agriculture, Nature and Outdoor Recreation) areas (adjacent)

Decisions for Kitemill:

Current decision - Technical Committee 17.06.2025 (case 61/25):

"Pursuant to the Planning and Building Act § 7, dispensation is granted from the airport zoning purpose in the municipal sub-plan for Lista flight and business park with a view to establishing a demonstration plant for wind power technology. The application is approved on the following conditions: - The test period shall contribute to increasing the knowledge base regarding the technology's impact and consequences for birds. Before testing is initiated, a plan shall be submitted on how the level of knowledge can be increased, for approval by the municipality. The plan shall be submitted to the County Governor of Agder for input prior to approval. - During testing there shall be an adequate level of personal safety. Other public authorities are required to confirm that an adequate safety level is in place."

Justification from the municipality: - The advantages of granting the dispensation are assessed as clearly greater than the disadvantages, cf. Planning and Building Act § 19-2 - The measure is of a temporary nature and consists of measures that are reversible and movable - Contribution to new technology that may entail energy production with less environmental intervention than current wind technology - Bird monitoring is required as part of the approval

In the municipal processing, statements were obtained from the CAA-N, the County Governor of Agder, neighbours and Farsund Lufthavn AS. All statements, neighbour comments and the developer's comments are publicly available in the municipality's case documents (archive case 25/00659-5).

Earlier decision - Technical Committee decision 22.03.2018 (case 18/41):

Kitemill has had a dispensation for test flying at Lista Airport since 2018. The original decision concerned a temporary kite test plant and was adopted unanimously with conditions on bird monitoring (archive case no. 2017/2456). The 2025 decision replaces and extends this dispensation to encompass the demonstration plant.

3.4 Schedule

Project phases

Year Phase Activity Systems
2026 Preparation Licensing process, test flying of R&D units, monitoring programme established 1-3 R&D
2027 Installation phase 1 Installation of stations M, N, O. Start-up of monitoring programme (field campaigns) 3
2028 Installation phase 2 Installation of stations A-L, grid connection completed, commissioning 12 (+3 = 15)
2029 Operating year 1 Full operation with 15 systems, operational shutdown during the busiest migration periods 15
2030 Operating year 2 Continued operation, evaluation and optimisation 15
2031 Operating year 3 Final operating year, end evaluation and reporting 15

GANTT chart

Activity                           2026        2027        2028        2029        2030        2031
                                   Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
─────────────────────────────────────────────────────────────────────────────────────────────────────────────
LICENSE AND PERMITS
  Concession application NVE       ████████████████
  Aviation permit                  ████████████████████████
  Grid connection agreement                    ████████████████

PREPARATION
  Test flying of R&D units         ░░░░░░░░████████████████
  Bird monitoring established          ████████████████────────────────────────────────────────────────────

INSTALLATION
  Stations M, N, O (3 units)                   ░░░░████████
  Stations A-L (12 units)                              ░░░░████████████████
  Grid connection and commissioning                        ████████████

OPERATION
  Year 1 - Full operation (15 systems)                                 ████████████████
  Year 2 - Operation and optimisation                                                  ████████████████
  Year 3 - Termination and evaluation                                                                  ████████████████

MONITORING AND REPORTING
  Field campaigns birds               --          --          --          --          --
  Annual reporting to NVE                                  ▲           ▲           ▲           ▲
  Final evaluation                                                                             ████████
─────────────────────────────────────────────────────────────────────────────────────────────────────────────
Legend: ████ = Main activity  ░░░░ = Preparation  ──── = Ongoing  ▲ = Milestone  -- = Field campaign (see chapter 9.7)

Main milestones (from EU Innovation Fund NAWEP)

Milestone Description Planned
MS9 All permits granted Q2 2027
MS12 Financial close Q2 2027
MS15 Construction works completed Q4 2028
MS16 Grid connection completed Q4 2028
MS17 Commissioning Q4 2028
MS18 Operating year 1 completed Q4 2029
MS19 Operating year 2 completed Q4 2030
MS20 Operating year 3 completed, project termination Q4 2031

3.5 Local vs. regional handling

The project is processed by NVE as the licensing authority under the Energy Act (Norwegian: energiloven). Farsund municipality has adopted a dispensation from the zoning purpose in the municipal sub-plan (cf. section 3.3).

The County Governor's appeal and parallel process

The County Governor of Agder advised against the dispensation in its consultation statement (9 May 2025), referring to bird interests and the knowledge base, and appealed the decision after the municipality made its decision on 17 June 2025. The appeal is under processing.

Farsund municipality has upheld its decision following an overall assessment in which the administration emphasised, among other things: - That the measure is temporary and reversible - That the main purpose is to increase the knowledge base regarding new technology - That studies of practical use in an area with abundant birdlife is a good way of increasing the knowledge base

CAA-N issued a positive consultation statement on 8 May 2025 (ref. 25/18542-2, signed by Section Head August Holte). The statement confirmed that Kitemill holds a valid operational authorisation in the specific category, that the planned activity is compatible with the existing danger area regime (END257) at Lista, and that the dispensation raises no objections from an aviation perspective. The statement is publicly available in full in Farsund municipality's case archive (case 25/00659-5, cf. Appendix 06).

All case documents, including the County Governor's statement and appeal, CAA-N's positive statement (ref. 25/18542-2), neighbour comments and the developer's comments, are publicly available in the municipality's archive (archive case 25/00659-5, cf. Appendix 06).

NVE has confirmed that the licensing process can proceed in parallel with the appeal case before the County Governor. The applicant acknowledges the County Governor's concerns regarding birds, and notes that the project's phased approach and monitoring programme (cf. section 9) is designed precisely to address the knowledge gap and document the technology's impact on birds under Norwegian conditions.


4. MAPS AND DELIMITATION

4.1 Overview map - Regional context

NVE-suitable regional overview map with the project area marked Figure 4.1: Regional overview map showing the project area's location in the Lister region, Agder. The ground stations (NAWEP) lie at Lista Airport west of Farsund. The map is NVE-suitable with compass needle, scale, legend, date, applicant and coordinate system.

Location: - Coordinates: 58.0995° N, 6.6264° E (centre of the airport) - Municipality: Farsund (municipality no. 4206), Agder county - Region: Lister region, Southern Norway - Distance to nearest town: Farsund centre approx. 8 km

Regional significance: Lista Airport is located on the Lista peninsula, Norway's southernmost peninsula. The area has good wind resources and an extensive ornithological observation history, contributing to the knowledge base for assessing airborne wind technology in the area.

4.2 Local overview map

NVE-suitable local overview map with the operating area Figure 4.2: Local overview map showing the operating area at Lista Airport in relation to nearby population centres (Lista, Vanse, Borhaug, Farsund), hamlets (Nordhassel, Råstad), nature reserves (Slevdalsvannet, Nesheimsvatnet) and cultural heritage (Nordberg fort, Lista lighthouse). The map is NVE-suitable with all required elements.

Surroundings: - North/north-east: Agricultural land, West Lista cultural landscape, Råstad hamlet, Nordberg fort (museum) - East: Lundevågen, Borhaug population centre - South: Nordhassel hamlet, Lista beaches, the North Sea - West: Slevdalsvannet nature reserve, Lista population centre

4.3 Plan delimitation, station locations and grid connection

NVE-suitable map with plan delimitation, stations, internal grid and grid connection Figure 4.3: Consultation-suitable NVE map showing proposed plan delimitation (light cyan), 15 ground stations (A-O), internal grid (underground cable), grid connection to Glitre Nett, and connection point at upgraded substation 74013. The map satisfies NVE's general map requirements (north arrow, scale, date, legend, applicant's name, coordinate system, and Kartverket (Norwegian Mapping Authority) topographic background).

Earlier station locations with grid infrastructure (illustration) Figure 4.3b: Illustration from project phase 1 of station locations (A-O) with internal grid infrastructure. The NVE-suitable version above (Figure 4.3) is the authoritative version.

The plan area encompasses: - Existing airport area within the fenced area - Total approx. 1.5 km² (150 hectares) - 15 possible station locations marked A-O - Central connection point at point E (near terminal building)

KML files (can be opened in public map services): - GRIDtegninger21.02.2025v1 m FoU punkt.kml - Grid layout with R&D point - Operasjonsområdet tegninger6.11.2024.kml - Operating areas - 250225_DangerArea.kml - Danger area (airspace)

4.4 Map with settlements and infrastructure

Map with buildings and roads Figure 4.4: Detail map showing the operating area (purple) in relation to buildings, roads and other infrastructure. Lista population centre west of the airport, Nordhassel south.

Nearest settlements:

Place Direction Distance from nearest station
Nordhassel (individual dwellings) South approx. 770 m (from station N)
Råstad (individual dwellings) North/north-east approx. 776 m (from station F)
Lista population centre West approx. 1,400 m (from station D)
Vanse centre North-east approx. 3,000 m
Borhaug population centre West approx. 4,000 m
Farsund town East approx. 8,000 m

Road infrastructure: - County road 43 (Listaveien) - south of the airport - Flyplassveien - internal access - No new roads required for the project

4.5 Map with environmental considerations

Map with protected areas Figure 4.5: Operating area (blue) in relation to all protected areas in the region (red hatched areas). The map shows the project area's position in relation to protected areas. The project area does not overlap with protected areas.

Protected areas in the vicinity:

Protected area Type of protection Distance Direction
Slevdalsvannet nature reserve Nature reserve approx. 330 m West
Lista wetland system Ramsar Adjacent South/West
Lista beaches Landscape protection area approx. 500 m South
Nesheimsvatnet Nature reserve approx. 1.4 km South-east

Buffer zones: No station locations are within the boundaries of protected areas. The minimum distance to Slevdalsvannet nature reserve is approx. 330 m (from station D).

4.6 Operating altitude

Note: For conventional wind power, tip height (the highest point of the rotor blade) is normally given. For AWE systems, the operating altitude (the height at which the kite flies during production) is the relevant measure.

Parameter Value
Minimum operating altitude 150 m above ground
Maximum operating altitude 500 m above ground
Typical operating altitude 200-400 m
Ground station height approx. 3 m

4.7 Roads and infrastructure

Note: AWE technology does not require access roads, in contrast to conventional wind power plants.

The project utilises existing infrastructure at the airport: - Existing asphalt runways and taxiways - Existing roads to the airport area - No new roads planned

4.8 Noise zone map

Noise zone map NAWEP - per-station and aggregated Figure 4.8: Noise zone map NAWEP. Dashed circles show per-station Lden 45 dB(A) radius (540 m). Filled contours show aggregated Lden from 15 units. The difference documents the summation effect of multiple simultaneous sources (+11.8 dB). Red line: T-1442/2021 (Norwegian noise-in-land-use-planning guideline) threshold value. See chapter 11.4 for full method.

4.9 Population density and SORA classification

Population density around NAWEP Figure 4.9: Estimated population density around NAWEP based on OSM building data and an assumption of average household size. Documents that the operating area and adjacent area are "Sparsely populated" in accordance with Kitemill's BVLOS operating permit. Population centres (Borhaug, Vanse, Farsund) lie 5-7 km from the plan area.

SORA 2.0 population categories with marking of Populated zone Figure 4.10: SORA classification in accordance with Kitemill's BVLOS approval (NOR-OAT-000294/000). Light blue area: plan area (Controlled ground area). Red semi-transparent overlay: "Populated" zones (> 25 p/km²). Cf. chapter 17.2 for containment architecture.

4.10 Distances from ground stations

Distance map NAWEP - County road 43, Flyplassveien, buildings Figure 4.11: Distances from each ground station (A-O) to County road 43 (red), Flyplassveien (orange) and built environment (brown = buildings, red = dwelling). Dashed lines show shortest distance to critical references. Nearest dwelling: 758 m, nearest building: 158 m, nearest county road: 854 m.

A detailed per-station table is included in chapter 7.5 and as Appendix 32.


5. TECHNICAL DESCRIPTION

5.1 AWE technology

Kitemill's AWE system in operation at Lista Airport. 1: Kite (wing), 2: Tether (line), 3: Ground station. Figure 5.1: Kitemill's AWE system in operation at Lista Airport. (1) Kite - rigid wing with VTOL propellers, (2) Tether - high-strength synthetic line, (3) Ground station with generator, winch and control systems.

Kitemill's system consists of: 1. Kite (wing): Rigid wing with approx. 17 m wingspan 2. Tether: High-strength synthetic line (up to 1,500 m) 3. Ground station: Generator, winch and control systems

5.2 Production cycle

Production cycle - production phase and return phase Figure 5.2: The production cycle. Left: Production phase - the kite flies in a circular motion and pulls out the tether while the generator produces electricity (constituting the main part of the cycle time). Right: Return phase - the tether is reeled in with low energy consumption while the kite returns to the starting position.

  1. Start: The kite is lifted to operating altitude using VTOL propellers (like a drone)
  2. Production (reel-out): The kite flies in a circular motion and pulls out the tether with great force. The tether force drives the generator on the ground station. This phase constitutes the main part of the cycle time.
  3. Return (reel-in): The kite is steered to a low-drag position, and the tether is reeled in with low energy consumption.
  4. Repetition: The cycle is repeated continuously. Net energy production is the difference between the production phase and the return phase.
  5. Landing: Automatic, in extreme weather or for periodic maintenance.

5.3 System specifications

Parameter Value
Capacity per system 100 kW (average)
Number of systems 15 (12 operational + 3 R&D units)
Total installed capacity (grid feed-in) 1.2 MW
Operating wind 5-25 m/s
Kite speed Up to 180 km/h (approx. 50 m/s)
Operating altitude 150-500 m above ground

5.4 Electrical system description (in accordance with the Energy Act Regulations § 3-2)

5.4.1 Generator per kite system (ground station)

Component Specification
Type Permanent magnet synchronous (PMSG)
Rated capacity per unit 100 kW (average over the production cycle)
Rotational speed Variable 0-5,000 rpm
Drive Direct drive on the winch shaft
Manufacturer/model To be specified in the design phase

5.4.2 Frequency converter / inverter

The generator delivers variable frequency (depending on the production phase in the kite cycle). The voltage is rectified to DC and inverted to 50 Hz AC for feed-in to the internal grid.

Component Specification
Type IGBT-based frequency converter (variable frequency → DC → 50 Hz AC)
Rated capacity per unit 150 kW
Filtering Filtered output to ensure grid quality
Grid quality In accordance with European and local standards for grid feed-in (EN 50160, IEC 61000 series)
Active monitoring Continuous monitoring of voltage, frequency, harmonics and power quality; automatic fault handling for values outside the tolerance range

5.4.3 Transformer hierarchy

Internal grid at 690 V AC out of each ground station - no local transformer at the ground stations. The central transformer station at Kitemill's substation (3 oil-filled units of 450 kVA each in parallel, 1,350 kVA total) steps the voltage up to 22 kV before connection to Glitre Nett's grid.

Component Specification
Central transformer station (Kitemill, upstream of internal grid) 3 oil-filled units of 450 kVA each (1,350 kVA total), 690 V AC → 22 kV, dimensioned for 1.2 MW + losses
Internal grid out of ground station 690 V AC (after frequency converter)
Glitre's transformer (74013) Separate unit, Glitre Nett's responsibility (22 kV / regional voltage)

5.4.4 Voltage level hierarchy

Level Voltage Description
Generator 400 V / 690 V AC (variable frequency) Low voltage out of each ground station
After frequency converter 690 V / 50 Hz AC To internal transformer
Internal grid (Kitemill) 690 V Cable between ground stations and central point
Connection point (Glitre) 22 kV At new substation 74013
Regional grid 110 kV Vanse TS

5.4.5 Metering

5.4.6 Certifications

Type Status
CE marking of electrical components Established as part of the delivery
IEC 61400 series (relevant parts for AWE-adapted use) Followed where relevant; specific standard for AWE under preparation in IEC TC 88
EN 50160 / IEC 61000 series (grid quality) Followed by frequency converters and control system
CAA-N operating permit BVLOS NOR-OAT-000294/000 (Appendix 05), VLOS ref. 22-02391-46 (Appendix 04)
Operations Manual QP-OPS-001 rev. 4.0 CAA-approved (January 2026)
Norwegian electrotechnical regulations (FEK, FSE, NEK 400) Followed for the entire plant

6. GRID CONNECTION AND ELECTRICAL INFRASTRUCTURE

6.1 Grid connection principle and interfaces

The grid connection of NAWEP is established through Glitre Nett AS pursuant to the obligation to connect (henteplikten), cf. Energy Act § 3-4. Glitre Nett confirms in a maturity assessment dated 21.11.2024 (ref. IN-00002114, Appendix 03) that the project is assessed as mature, and that connection of feed-in of 1.2 MW is operationally sound in the distribution grid, regional distribution grid and transmission grid.

Division of work and interfaces

Cost allocation

Kitemill AS covers the construction contribution (anleggsbidrag) for any grid reinforcements that may be required by the feed-in, cf. the Regulations on economic and technical reporting etc.

6.2 Connection point and voltage level

6.3 Capacity and operational soundness

Glitre Nett confirms in its maturity assessment (ref. IN-00002114, dated 21.11.2024, cf. Appendix 03):

Glitre explicitly confirms that there is capacity for both NAWEP (1.2 MW) and Solkraft Lista (planned in parallel) in the relevant grid. The connection is operationally sound on ordinary terms, and there are no conditions on disconnection or production restrictions for NAWEP.

6.4 Transformer and electrical infrastructure

Component Description
New substation (Glitre) Replaces existing 74013-LISTA FLYSTASJON, no new land take beyond the existing station area
Metering points 2 high-voltage (Kitemill + Solkraft Lista)
Distribution voltage level 22 kV
Kitemill central transformer station 3 oil-filled units of 450 kVA each (1,350 kVA total), 690 V / 22 kV, dimensioned for 1.2 MW + losses (cf. section 5.4.3)
Ground stations No local transformer - 690 V AC out directly from frequency converter
Transmission voltage level 110 kV (Vanse TS)
Cable routing Underground cable in existing and new corridors (total length approx. 5,114 m, cf. tender from external contractor)

6.5 Internal grid

Grid specifications: - Total cable length: 5,180 m - Maximum capacity per unit: 180 kW - Continuous combined delivery: 1,200 kW - Units: A-M with individual distances

[See Appendix 17: Grid drawings (Shapefile)]

6.6 Installed capacity and annual production

Parameter Value
Installed capacity (grid feed-in) 1.2 MW
Production units 12 units (stations A-L)
R&D units 3 units (stations M, N, O) - not included in the production calculation
Capacity per unit 100 kW average
Expected annual production (mature operation) 4.2 GWh
Full-load hours (mature operation) 3,500 hours

Production ramp-up plan:

Year Full-load hours Annual production
2027 800 hours 960 MWh
2028 1,200 hours 1,440 MWh
2029 2,000 hours 2,400 MWh
2030+ 3,500 hours 4,200 MWh

Calculations based on PowerSim (version 37), validated against KM1 prototype testing.

[See Appendix 03: Maturity assessment Glitre Nett 21.11.2024]

6.7 Climate benefit and resource efficiency

6.6.1 Greenhouse gas savings

Production of renewable energy displaces fossil-based power production in the European power market. The EU Innovation Fund's GHG calculation methodology uses an emission factor of 0.15 tonnes CO2 equivalents per MWh for the reference grid. Based on this, the project's climate contribution can be estimated:

Parameter Value
Emission factor reference grid (EU) 0.15 tonnes CO2e/MWh
Annual production at mature operation 4,200 MWh
Estimated annual CO2 savings at mature operation ~630 tonnes CO2e

Production will ramp up gradually in line with technology maturation (cf. section 6.5). In an early phase, actual production and thus climate effect will be lower than at mature operation. The ramp-up plan reflects that this is a new technology where operating experience and adaptation to local conditions will affect the production level.

For comparison, 4,200 MWh corresponds to the electricity consumption of approximately 260 Norwegian households (based on average consumption of 16,000 kWh/year, Statistics Norway).

6.6.2 Resource efficiency

AWE technology differs substantially from conventional wind power in material consumption and land take. Kitemill estimates, based on the company's system design, indicate the following comparisons:

Parameter Conventional wind power AWE (Kitemill)
Material consumption ~500 tonnes per MW ~50 tonnes per MW
Ground footprint per unit ~2,000 m² (foundation, road, hardstanding) ~36 m² (ground station 6×6 m)
Permanent terrain interventions Concrete foundation, access roads, hardstandings None - movable steel frame
Infrastructure Special transport, crane operations, access roads Standard vehicles, underground cables

These figures are based on the company's own calculations and will be verified through the NAWEP project. The fundamental material saving follows from the AWE system replacing tower, nacelle and rotor blades with a light wing profile and an anchoring tether. The ground station with generator constitutes the main part of the material consumption.

The low material intensity also gives a shorter Energy Payback Time (EPBT). Faggian et al. (2019) estimate EPBT for AWE systems at approx. 5 months, compared with approx. 9.5 months for conventional wind power. The climate footprint per kWh produced is correspondingly reduced.

6.6.3 Reversibility

A significant property of AWE installations is that they can be removed without lasting traces in the terrain. The ground stations are bolted to the ground without concrete foundations, and internal cable infrastructure is laid as underground cable. Upon project termination, the area can be restored to its original condition without costly demolition works.

6.8 Economy

6.7.1 Investment costs (CAPEX)

All figures are estimates at pilot/demo level (immature technology) and will be adjusted in detailed design. Ordinary market-based uncertainty intervals are included.

Cost item MNOK Basis
Kite systems (kite + ground station + line + control system), 15 x 3 MNOK 45.0 Kitemill estimate (pilot, immature)
Civil works and trenches (stages A+B+C + options) 3.42 Written tender from external contractor, 27.08.2025 (exempt from public access under Public Access Act § 13)
Electrical infrastructure (3 x 450 kVA transformer, 22 kV internal grid, cabling - materials, excl. laying) 8-10 Kitemill estimate
Construction contribution to Glitre (upgrade of substation 74013) 2-4 Depends on Glitre's final tender
SCADA, monitoring and control systems 3-4 Kitemill estimate
Engineering, permits, expert assessments 3-4 Kitemill estimate
Construction works (electrical assembly, commissioning, testing) 4-5 Kitemill estimate
Contingency (~12%) 8-10 Standard practice
Total CAPEX (pilot) 76-85 MNOK

The tender from the external contractor for civil works is costed and is enclosed as Appendix 09 (EXEMPT FROM PUBLIC ACCESS) pursuant to Public Access Act § 13 (trade secrets).

6.7.2 Operating costs (OPEX) per year

Item MNOK/year Source
Baseline O&M (based on LCOE model KM2 series production) ~0.8 LCOE model (45.5 EUR/kW/year x 1,500 kW)
Pilot/R&D supplement:
- Monitoring and operation (R&D operating personnel) 1.5-2.0 Kitemill estimate
- Bird monitoring and biological field campaigns included Annual field campaign in line with mitigation measures (cf. chapter 9)
- Grid tariff and feed-in tariff 0.2-0.4 Standard tariff
- Insurance 0.3-0.5 Kitemill estimate
- Ground rent and administration 0.3-0.5 Kitemill estimate
Total OPEX (pilot) ~3.5-5.0 MNOK/year

The OPEX estimate includes an annual cost item for biological field campaigns and bird monitoring in accordance with the mitigation measures described in chapter 9. The item finances independent professional follow-up of migratory birds and biodiversity throughout the operating phase, and forms part of the licensee's commitment to monitoring and reporting.

6.7.3 Support schemes

Scheme Status
EU Innovation Fund (NAWEP) Awarded
AWE-KM2 grant (Horizon Europe) Confirmed
SkatteFUNN Confirmed
Research Council of Norway IPN Under application (decision May 2026)
Enova Application planned - subject to license being granted
Guarantees of origin (Norwegian renewable guarantee) Registration planned from commissioning

The project has been awarded EU Innovation Fund support through the NAWEP programme and has secured the AWE-KM2 grant. Supplementary financing is expected through the Research Council of Norway IPN and the SkatteFUNN scheme. Enova support is planned to be applied for after the license has been granted, as Enova's R&D/demo programme requires an established license.


7. LAND USE AND PLANT COMPONENTS

7.1 Ground station

Render of Kitemill's ground station with kite in parked position. The person illustrates scale.

  • Size: approx. 6 x 6 metres footprint
  • Height: approx. 3 metres
  • Foundation: Steel frame, no concrete foundation
  • Reversibility: Can be removed without lasting traces

Figure 7.1: Ground station with kite in parked position. The person illustrates the system's scale.

7.2 Service area

7.3 Land take

The project is designed with minimal permanent land take. The table below shows total direct intervention based on Kitemill specification and a written tender from an external contractor (ref. chapter 6.7).

Type of intervention Permanent (m²) Temporary (m²)
Ground stations 15 x 25 m² (gravel pad 5 x 5 m per unit) 375 -
Civil works area around ground stations (external contractor's assumption: 30 m² per unit) - 450
Cable trench in field (4,556 m x approx. 1 m during construction phase; restored after construction) 0 approx. 4,556
Cable trench in asphalt (72 m) with re-asphalting 144 144
Drilling pits, 9 units 0 approx. 27
Upgrade of existing substation 74013 (Glitre) 0 -
Kitemill's internal transformers (integrated in substation 74013) 0 -
Rig area, storage and access road - approx. 2,500
Total ~520 m² ~7,700 m² during construction phase

7.4 Construction phase

The construction period is carried out in two phases over a total of approx. 15 months, divided between 3 months in 2027 (installation of 3 R&D systems M, N, O) and approx. 12 months in 2028 (installation of stations A-L, grid connection and commissioning). Continuous on-site construction activity in each phase is approx. 3 and 12 months, respectively. Planned commissioning is 31.12.2028, cf. schedule in chapter 3.4.

The construction phase encompasses the following activities:

The construction works entail no blasting, spoil deposits or permanent terrain interventions beyond a cable trench in asphalt that is re-asphalted. Noise and vibrations from construction machinery will be limited and of a temporary nature, equivalent to ordinary construction activity. Upon completion, affected areas are restored to their original condition.

7.5 Distances from ground stations to roads and built environment

No ground station is closer than 854 m to county road 43 or 596 m to Flyplassveien. The nearest building in the airport area (including hangars and technical buildings) lies 158 m from the nearest ground station. The nearest dwelling is 758 m from the nearest ground station. All distances are measured as the shortest line in EPSG:25833 (ETRS89/UTM33N), based on actual station locations in the shapefile and road/building data from OpenStreetMap.

A detailed per-station distance table and map are enclosed as Appendix 32 - Distance calculations.


8. BIODIVERSITY

8.1 Area description

The Lista area has recognised natural values and includes: - Ramsar status (international wetland protection since 1996) - 1.3 million bird observations in the Norwegian Species Database (Artsdatabanken) - 34 red-listed bird species documented in the area

8.2 Protected areas

Map with Slevdalsvannet and Nesheimsvannet nature reserves Figure 8.1: Operating area (purple) in relation to the nearest nature reserves: Slevdalsvannet (west, green) and Nesheimsvatnet (south-east, green). Both form part of the Lista wetland system (Ramsar).

Protected area Type Distance
Slevdalsvannet nature reserve Nature reserve approx. 330 m west
Lista wetland system Ramsar Adjacent
Lista beaches Landscape protection area approx. 500 m

8.3 Habitat types

The plan area mainly comprises airport areas and cultivated land. No threatened habitat types are registered within the plan area.

In adjacent areas, the following are registered: - Oceanic raised bog (NiN), associated with the habitat type Atlantic raised bog - Salt marshes - Coastal heath

These are not affected by the project.

8.4 Red-listed species

Map with protected areas and species hotspots Figure 8.2: Operating area (blue) shown with protected areas (red hatched areas) and species records from the Norwegian Species Database (colour intensity indicates registration density). Most records in the area are linked to birds. The project area lies in an area of moderate registration density compared with surrounding nature protection areas.

Based on the Norwegian Species Database, rare coastal plants are registered in surrounding areas, including sea holly and soft mermaid grass. The species are associated with coastal stretches outside the plan area.

8.5 Assessment

The plan area is already heavily affected by human activity. The AWE plant will have limited direct impact on habitat types since: - No new roads are built - Minimal interventions in the ground - Operation takes place in the airspace


9. BIRDS AND MIGRATORY BIRDS

This assessment has been prepared in cooperation with Arnold Håland, NNI Resources AS, based on NNI Report 520 (2018) and updated assessment (2024).

9.1 Summary

Lista is a recognised bird locality. The applicant has prepared a comprehensive plan for mitigation measures and monitoring in accordance with the Nature Diversity Act §§ 8-12.

9.2 Relevant species

The following species have been specifically considered in the monitoring programme: 1. Marsh harrier 2. Common crane 3. Lesser black-backed gull 4. Common swift 5. Barn swallow 6. Skylark 7. Meadow pipit

9.3 Knowledge base

Existing knowledge: - NNI Report 520 (2018), commissioned by Kitemill: 110 hours of fieldwork - Norwegian Species Database: 1.3 million observations - Updated assessment by Arnold Håland (2024)

Knowledge building: Existing surveys of the bird life at Lista are extensive. The project will further strengthen the knowledge base in the following areas: - Spring migration: Surveying of the spring migration will supplement existing data on the autumn migration. - Altitude distribution: Systematic recording of birds' flight altitudes in the plan area through the seasons. - AWE-specific response: Documentation of bird behaviour in the vicinity of AWE systems, contributing to the knowledge base for this new technology.

This knowledge building forms a central part of the project's monitoring programme, cf. Nature Diversity Act § 8.

9.4 Assessment of scaling from 1 to 15 systems

Arnold Håland (NNI) has, in an updated assessment (November 2024), assessed the consequences of scaling from a single test unit to 15 simultaneous systems (12 production units + 3 R&D units). Main findings:

Breeding birds: In addition to migratory birds, Lista is an important breeding area for several species. Among the species listed in 9.2, skylark and meadow pipit breed in the cultural landscape around the plan area, and the open agricultural landscape on Lista also hosts other waders (lapwing, curlew, oystercatcher) that are sensitive to disturbance during the breeding season (April-July). Professional assessment of impact on breeding birds is part of Håland's updated assessment (2024) and is included in the monitoring programme (chapter 9.7) through dedicated breeding-season campaigns. The breeding season is treated as an operationally sensitive period on a par with migration periods in the mitigation measures (chapter 9.6).

9.5 Phased ramp-up and risk management

To uphold the precautionary principle (Nature Diversity Act § 9), the project is structured with a gradual ramp-up where operation is adapted based on accumulated knowledge:

Year Activity Bird-related measures
2026 1 system, daytime flying only Negligible burden. Monitoring programme established (field campaigns spring/summer/autumn)
2027 Up to 4 systems (stations K, M, N, O) Daytime and some night-time flying under observation. Focus on spring and autumn migration periods
2028 12 systems Operational shutdown in the most active migration period
2029 Partial operation with observation Evaluation of impact based on data from 2028. Adaptation of operating pattern
2030 Full operation Subject to the impact being assessed as acceptable in 2029

Most bird migration takes place at night. The most effective mitigation measure is operational shutdown during periods of high migration activity. In the event of unacceptable consequences, the plan can be adjusted or reversed.

The approach has been developed in dialogue with NNI Resources AS and is based on the knowledge base from the 2018 study and Håland's updated assessment (2024). Kitemill commits to sharing all collected data with the County Governor and NVE throughout the project period.

9.6 Mitigation measures

  1. Gradual ramp-up over 5 years
  2. Daytime flying only in 2026
  3. Operational shutdown / restriction during the busiest migration periods (from 2028) and during the vulnerable breeding season (April-July) where monitoring documents the need
  4. Bird monitoring through field campaigns (spring, breeding season, autumn)

9.7 Field plan 2026 and subsequent years

Period Number of sessions Focus
Spring (April-May) 2 Spring migration and early breeding
Breeding season (May-July) 2 Breeding birds — skylark, meadow pipit, lapwing, curlew, oystercatcher and other waders
Autumn (Sept-Oct) 2 Autumn migration

10. LANDSCAPE AND VISUAL IMPACTS

10.1 Landscape character

The Lista peninsula is characterised by: - Flat, open coastal landscape - Agricultural landscape with stone walls - Historic airport profile - Exposed to the North Sea

10.2 Visual impact

Aspect Assessment
Visibility Kites visible on a clear day up to 3-5 km
Movement Dynamic, circular motion
Light marking and obstruction lights See section 10.2.1
Reversibility Fully reversible, no permanent structures at altitude

10.2.1 Light marking and visual marking

Marking of aviation obstructions is regulated by regulation BSL E 2-1 (FOR-2014-07-11-980). The regulation was updated in 2023-2024 and, under § 13 third paragraph, expressly covers anchored unmanned aircraft, which is the definition that covers Kitemill's kite system.

Basic requirements under BSL E 2-1 § 13 (3):

Height above ground Colour marking of tether Light at the top
60-100 m Required Low-intensity light
100-150 m Required Medium-intensity light
Above 150 m Required High-intensity light

NAWEP operates in the altitude range 150-500 m, and would thus, on a direct reading of the regulation, fall under the category "above 150 m".

CAA-N published in 2023 an updated guidance to BSL E 2-1. The guidance to § 13 third paragraph reads (quote):

"An object can be defined as both an aviation obstruction and an aircraft and thus be required to comply with the requirements of both regulations, where AIC-N 15/23 13 OCT provides an explanation. The use of unmanned aircraft above 120 metres is subject to application, and appropriate marking is addressed through SORA, taking the regulation on marking of aviation obstructions as a starting point in so far as this is practicable and does not defeat the purpose of the activity or operation to be conducted. Assessments will, for example, be made when applying for research and development work."

NAWEP satisfies both regulatory regimes:

For the actual marking design (tether, kite, light), CAA-N exercises discretion under BSL E 2-1 § 7 (3) and § 21 (2), combined with the R&D clause in the guidance to § 13 (3). This gives CAA-N authority to adapt the marking requirements to NAWEP's operating pattern and research purpose. The regulatory framework is publicly documented through: (i) AIC-N 15/23 13 OCT (CAA-N's circular explaining BSL E 2-1 § 13 in combination with the R&D clause, quoted above), (ii) BSL A 7-2 (Norwegian Regulation 2024-11-01-2777 on unmanned aviation) implementing EU 2019/947, and (iii) Farsund municipality's public case archive 25/00659-5 (cf. Appendix 06) which contains CAA-N's consultation response in full. Kitemill has ongoing dialogue with CAA-N's section for unmanned aviation regarding these matters.

10.3 Visualisations

The following visualisations show the AWE system in operation at Lista Airport. The images have been generated with 3D modelling based on actual station locations and operating altitudes.

Methodology for photo viewpoints: The visualisations from ground level (Figures 10.5 and 10.6) have been produced from Ore krysset (EUREF89 UTM-33: E 8,006.80 / N 6,471,450.86), the nearest publicly accessible viewpoint with unobstructed view towards the project area, and represent the actual visual impression a member of the public will have of the plant. The 3D oblique projections from a bird's-eye perspective (Figures 10.3 and 10.4) are only intended as technical overview maps to illustrate the operating pattern in plan view; they are not assessments of visual impact from publicly accessible viewpoints. Actual photographs of the existing KM1 prototype in operation (Figure 10.7) supplement the documentation of a kite in the air, with explicit reservation that the prototype's location deviates from the planned NAWEP stations.

10.3.1 Overview images - station locations

3D view of station locations seen from the south Figure 10.1: 3D view from the south (oblique perspective) showing selected station locations (F, H, K, M, N, L) along the runway. The lines illustrate connections between stations and operating areas.

3D view of all stations with operating pattern Figure 10.2: Overview of all 15 stations (A-O) with visualised circular movements for the kites in operation. Seen from the south-east (oblique perspective) with the sea in the background.

10.3.2 Technical overview maps - operating pattern in plan view

Note: The figures below are 3D renderings from a bird's-eye perspective and are only technical overview maps. They are not intended as assessments of visual impact from publicly accessible viewpoints - for that, refer to Figures 10.5 and 10.6 (seen from Ore krysset).

3D rendering with operating circles from above Figure 10.3: 3D rendering from above (technical overview map, bird's-eye perspective) showing the operating circles of all 15 systems in plan view. Each cylinder represents the area in which one kite operates in circular motion. Not a publicly accessible viewpoint.

3D rendering with operating circles - alternative angle Figure 10.4: 3D rendering, alternative oblique angle from above (technical overview map) showing the operating pattern in relation to the runways and surrounding landscape. Not a publicly accessible viewpoint.

10.3.3 Visualisation seen from a publicly accessible viewpoint (Ore krysset)

Visualisation of circular motions against the sky, seen from Ore krysset Figure 10.5: Visualisation seen from Ore krysset (public road, nearest accessible viewpoint towards the project area; EUREF89 UTM-33: E 8,006.80 / N 6,471,450.86) showing the kites' circular motions against the sky. Operating altitude 200-400 m above ground.

Visualisation of all kites in operation, seen from Ore krysset Figure 10.6: Visualisation seen from Ore krysset (EUREF89 UTM-33: E 8,006.80 / N 6,471,450.86) showing all 15 kites in operation. The kites (17 m wingspan) are visible as small objects against the sky at typical operating altitude.

10.3.4 Actual photo - existing KM1 prototype at Lista

Photo from actual flight with the KM1 prototype at Lista Figure 10.7: Photo from actual flight with Kitemill's existing KM1 prototype at Lista Airport. Reservation: The KM1 prototype is at a different location from the planned NAWEP stations (A-O) and is shown here only to document the actual visibility of a kite in operation against the sky. The kite does not cover the solar disc from normal operating altitude, and shadow flicker has not been observed.

10.3.5 Methodology

The visualisations have been prepared with the following methodology: - Background images: Satellite imagery and 3D terrain model from publicly available sources - Station locations: Based on actual coordinates from the planned grid layout - Operating circles: Visualised as cylindrical volumes with radius corresponding to tether length - Scale: The kites are presented at actual size (17 m wingspan) relative to the surroundings

Assessment of visual impact: - The kites are visible as small objects against the sky at distances above 500 m - No permanent structures above ground level beyond ground stations (approx. 3 m height) - Dynamic movement (circles) differs from static wind turbines - Visual impact is assessed as moderate. The smaller physical dimensions of AWE systems and the absence of permanent structures at altitude give a different visual character from conventional wind power


11. ACOUSTICS

11.1 Knowledge base

The knowledge base for the acoustic assessment is based on the following sources:

  1. Inge Hommedal (2016): Early study for Kitemill conducted by an engineer with a background from Kjelde akustikk AS and SWECO.

  2. Bouman, N. (2023): Acoustic field measurements of Kitemill's KM1 system carried out at Lista Airport, March 2023. MSc thesis, Delft University of Technology. Available: https://repository.tudelft.nl/record/uuid:390a153c-0114-44c8-8b43-d9efc3e8cdd1

  3. T-1442/2021: The Norwegian guideline for the treatment of noise in land-use planning is used as the basis for threshold values.

The plan area lies within an existing noise zone from air traffic, mapped by Sweco (2020) as part of the airport's sequence provisions. The acoustic contribution from the AWE plant comes in addition to this existing burden.

11.2 Sound sources during AWE operation

The AWE system's sound sources are fundamentally different from conventional wind power:

Sound source Operating phase Character
Tether vibrations Production (main source) Tonal, whistling sound
Aerodynamic wing noise Production Broadband
VTOL propeller Take-off/landing Low-frequency (~100 Hz)
Generator/winch Continuous Low level

11.3 Measured values from Lista (Bouman 2023)

Acoustic field measurements of Kitemill's KM1 test system were carried out at Lista on 27 March 2023 with class 1 instrumentation (Brüel & Kjær 4189 microphone, B&K 2250 sound level meter, calibrated 114 dB/1000 Hz). The measurements are documented in Bouman, N. (2023) Aeroacoustics of Airborne Wind Energy Systems, MSc thesis at TU Delft.

11.3.1 Measurement set-up and geometry

Parameter Value
Test date 27 March 2023
Test system Kitemill 30 kW test system
Ground wind (measurement) 9.1 m/s from NW
Kite speed 0-40 m/s
Kite flight altitude above ground (z) 150-350 m
Horizontal distance kite-microphone (d) 600-1,100 m
Slant range microphone-kite (r = √(d² + z²)) 620-1,150 m
Microphone location ~3 m from winch at ground level

11.3.2 Measured noise levels

Parameter Value at microphone
OASPL (Z-weighted) production phase ~75-90 dB
OASPL(A) production phase ~65-75 dB(A)
OASPL(A) start-up phase ~75-90 dB(A) (higher due to low-frequency content)
Dominant peak frequencies 1,500 Hz and 2,000 Hz
Secondary frequencies 20 Hz (constant), 180 Hz (low speed), 300-500 Hz (broadband)

Important note on source decomposition: The microphone was located ~3 m from the winch and simultaneously 620-1,150 m (slant range) from the kite. The measured OASPL(A) is a combined measurement of:

  1. Winch noise from the ground station (close to the microphone)
  2. Kite noise from a slant range of 620-1,150 m

Bouman does not separate these two contributions physically. For NAWEP propagation calculation, they are therefore treated as two separate point sources.

11.3.3 Established scaling laws

11.4 Assessment of noise at the nearest settlement

Note: Illustrative analysis

The calculations and scenarios presented in this chapter are an example based on KM1 test data (Bouman 2023, 30 kW) scaled to KM2 size (100 kW). The KM2 system is still under development, and noise is one of the design parameters being optimised through the project's development phase. Kitemill is actively working on trailing-edge design, tether design and operational algorithms to minimise noise at the production system. Based on this work, Kitemill expects the KM2 plant to lie within recommended threshold values (T-1442/2021 Lden 45 dB(A) at noise-sensitive built environment).

The analysis in section 11.4 illustrates calculation methodology and operational scope, and provides a basis for the mitigation measures and commitments in section 11.7. Final documentation of actual noise levels takes place through the measurement programme after commissioning of the first KM2 system (cf. section 11.7.3).

For a correct geometric calculation, we distinguish between the two sources and use slant range (3D distance) from the kite to the receiver, not only horizontal distance. The ground station is treated separately as a point source at ground level.

11.4.1 Geometric model

Each of the 15 NAWEP units has two sound sources:

Slant range from kite to receiver: r_i = √(d² + h²) where d is horizontal distance from kite and h is altitude.

The sound pressure level at the receiver from one source i (spherical spreading, free field):

Lp_i = Lw_i - 20·log10(r_i) - 8

where Lw_i is the source's sound power level and r_i is the distance from source i to the receiver. The distance enters explicitly into each Lp_i.

When multiple independent sources contribute simultaneously, the sound pressure levels are summed logarithmically (energetically):

Lp(receiver) = 10·log10(Σ 10^(Lp_i / 10))

Combined formula in which the distance is visible:

Lp(receiver) = 10·log10(Σ 10^[(Lw_i - 20·log10(r_i) - 8) / 10])

Each of the 30 sources (15 ground stations + 15 kites) has its own distance r_i to the receiver, and thus its own contribution Lp_i. The nearest source dominates; halving the distance gives +6 dB in contribution from that source.

Geometry for noise calculation - operating volume and slant range Figure 11.0: Geometry for noise calculation at NAWEP. The operating volume (cyan) is clipped against a 430 m buffer around the nearest dwelling (Nordhassel/Råstad, d = 770 m). The buffer is physically anchored: at slant range 430 m, one kite gives Lp = 105 - 20·log10(430) - 8 = 44.3 dB(A) - just below the T-1442/2021 threshold value 45 dB(A). Example: kite at 25° elevation, 380 m tether, h = 161 m. Slant range to dwelling 447 m, Lp_kite = 44.0 dB(A); winch contributes 27.0 dB(A); sum per unit ≈ 44.1 dB(A). The buffer ensures per-kite compliance; for cumulative Lden ≤ 45 dB(A) from all 15 stations, additional mitigation measures are required (section 11.7).

11.4.2 Sound power levels for KM2 (scaled from Bouman)

Based on decomposition and scaling from the 30 kW test system to 100 kW KM2:

Source Lw scaled to KM2 Justification
Kite (KM2, 100 kW) ~105 dB(A) Bouman data + scaling 10·log10(100/30) = +5.2 dB
Winch/ground station (KM2) ~92.7 dB(A) Typical for electromechanical winch 100 kW + scaling

11.4.3 Calculated noise levels at the nearest noise-sensitive settlement (~770 m from the nearest ground station)

The dwelling closest to a ground station lies in Nordhassel (south of the runway, approx. 767 m from station N) and Råstad (north/north-east of the runway, approx. 776 m from station F). These two hamlets represent the dimensioning receiver points for the noise assessment. The calculations below are made for 770 m horizontal distance.

Two scenarios are presented:

Scenario A - Realistic operation (kite at h = 300 m AGL above the ground station):

Contribution Lp at Nordhassel/Råstad (770 m horizontal)
Kite at (sx, sy, 300 m), slant range = √(770² + 300²) = 826 m 105 - 20·log10(826) - 8 = 38.7 dB(A)
Winch at (sx, sy, 0), distance = 770 m 92.7 - 20·log10(770) - 8 = 27.0 dB(A)
Sum from one unit ~38.9 dB(A)
Sum from 15 units (realistic geometry) ~43-47 dB(A) worst case

Scenario B - Worst case (kite at h = 150 m AGL, lowest permitted production altitude):

Contribution Lp at Nordhassel/Råstad (770 m horizontal)
Kite at (sx, sy, 150 m), slant range = √(770² + 150²) = 784 m 105 - 20·log10(784) - 8 = 39.1 dB(A)
Winch 27.0 dB(A)
Sum from one unit ~39.2 dB(A)
Sum from 15 units ~44-48 dB(A) worst case

Lden assessment: The plant must be able to operate around the clock (wind-dependent production). Lden = Lp_max without daytime advantage. The calculations above (38.7-39.1 dB per kite alone; 43-48 dB sum from 15 units) are therefore directly comparable with the T-1442/2021 threshold value Lden 45 dB(A). Per-kite Lp is safely below the threshold; the sum from 15 units lies at the outer margin and requires mitigation measures (section 11.7) for robust margin.

11.4.4 Hypothetical worst case: kite directly above settlements

In a purely geometric worst case where the kite is flown at the lowest permitted altitude (150 m) directly above a dwelling in Nordhassel or Råstad, one kite alone gives:

Lp = 105 - 20·log10(150) - 8 = 53.5 dB(A)

This would exceed the threshold value. Such flying is excluded through buffer restriction and operational measures (section 11.7), including geo-fence and restrictions in the Operations Manual that prevent flying closer than 430 m from a dwelling.

11.4.4a Buffer conclusion: 430 m per-kite buffer

The correct buffer around noise-sensitive settlements is physically anchored in the T-1442/2021 threshold value:

Per-kite buffer = 430 m (giving Lp = 105 - 20·log10(430) - 8 = 44.3 dB(A) from a single kite, just below 45 dB(A)). This is the minimum slant range from each kite to the nearest dwelling.

Distance r Lp one kite Assessment
300 m 47.5 dB(A) Above threshold - insufficient
398 m 45.0 dB(A) Exact threshold value
430 m 44.3 dB(A) Selected buffer - 0.7 dB margin

Cumulative Lden from 15 stations also requires mitigation measures. The per-kite buffer alone does not solve accumulation: with all 15 stations in operation and the nearest kite at 430 m from a dwelling, the summed Lp is calculated to be approx. 47-48 dB(A). As NAWEP must be able to operate around the clock (wind-dependent production, no daytime restriction), Lden = Lp without favourable correction. The sum from 15 stations at 430 m nearest kite therefore lies 2-3 dB above the threshold value.

To ensure Lden ≤ 45 dB(A) at the nearest dwelling, a combination of measures is therefore required (section 11.7):

The final Lden value at settlements is verified and documented through the measurement programme (section 11.7.4); operation is iteratively adjusted so that the threshold value is observed under actual conditions.

11.4.5 Noise zone map - per station and aggregated

The calculation models the kite envelope (30° elevation, tether 350-400 m) and logarithmic summation of noise from all 15 units. The sound source is the kite in the air, not the ground station - for each receiver point, the kite is placed on the geofence boundary (400 m sphere from ground station, minimum elevation 30°/h_min ≈ 175 m) closest to the receiver, and the slant distance from kite to receiver is used in the sound propagation. The winch, which is actually on the ground, is calculated from the ground station's position (Lw = 92.7 dB(A)).

Noise zone map - per-station envelope and aggregated contour Figure 11.1: Noise zone map NAWEP - operating scenario with mitigation. Assumptions: KM2 designed for low noise (Lw_kite = 95 dB(A), Bouman measures -10 dB), 12 active stations during the night period (M, N, O marked with open red circles are night shutdown 23:00-07:00 cf. license commitment). Dashed circles show per-station kite envelope (geofence projection, ~360 m) - the horizontal range of the kite at minimum operating altitude, not an actual Lden 45 dB contour. A single KM2 kite produces a maximum of approx. 42 dB(A) at ground (directly below, h_min = 175 m, slant_min = 175 m → Lp = 95 - 20·log(175) - 8 = 42.1 dB), so the threshold value Lden 45 dB(A) can only be exceeded by the logarithmic sum of multiple stations. Filled contours show summed Lden, and the strong red line is the summed Lden 45 dB(A) (T-1442/2021 threshold value). Dwellings in Nordhassel and Råstad lie clearly outside the 45 dB contour. This is the expected operating picture under the license conditions.

11.4.5a Logarithmic summation - why 15 stations give more than one

Sound from multiple independent sources is summed logarithmically (energetically):

Lp_total = 10·log10(Σ 10^(Lp_i / 10))

where Lp_i = Lw_i - 20·log10(r_i) - 8 for each source i. The distance r_i from each individual source enters explicitly into the individual Lp_i. The formula thus says: calculate each contribution based on its own distance, then sum energetically.

Case A - all sources equally far away (same r):

If all sources are equally far from the receiver and have the same Lw, the contribution from each source is equal and the sum becomes 10·log10(N) above one source:

Number of sources Addition above one source (equal distances)
1 0 dB (reference)
2 +3 dB
4 +6 dB
10 +10 dB
15 +11.8 dB

Case B - sources at different distances (NAWEP reality):

In NAWEP, distance to receiver varies considerably from station to station. For a Nordhassel dwelling, the nearest station is approx. 765 m away while the furthest is ~1,700 m. The contributions from distant stations are substantially smaller than from the nearest:

Distance r Lp from one kite (Lw=105) Contribution in sum (relative to nearest)
765 m 39.3 dB 1.00 (reference)
1,000 m 37.0 dB 0.59
1,500 m 33.5 dB 0.26
2,000 m 31.0 dB 0.15

The sum of 15 stations at Nordhassel (actual distances) gives only ~+8 to +9 dB above the nearest individual contribution - not +11.8 dB. This is because the nearest station dominates the sum and distant stations contribute little.

Practical consequence for NAWEP: - Per-station kite envelope: approx. 360 m horizontal geofence projection from the ground station. This is NOT a noise contour - one KM2 kite gives a maximum of ~42 dB(A) at the ground (h_min = 175 m, slant_min = 175 m, Lw_kite = 95 dB), so Lden 45 dB(A) is never exceeded by a single station. - Summed Lden 45 dB(A) contour: only the logarithmic sum of multiple stations can exceed the threshold value. The contour in Figure 11.1 therefore extends beyond the per-station envelopes. - Nearest station dominates: Shutting down the nearest station gives a 3-5 dB reduction; shutting down a distant station gives <1 dB. Therefore, selective operational shutdown of M, N, O (section 11.7.1 step 3) is effective.

This means that mitigation measures must be considered both for the nearest stations (largest contribution) and for the entire plant (cumulative effect). Bouman measures (section 11.7.1 step 1) reduce Lw_i for ALL stations and are the most effective single measure.

11.4.5b Realistic operating scenarios at Nordhassel and Råstad

Based on actual station distances to the nearest dwellings in Nordhassel (58.089°N, 6.635°E) and Råstad (58.108°N, 6.635°E), operating scenarios have been calculated taking into account wind direction and operating strategy (section 11.7.1 step 3).

Assumptions: - Lw_kite = 105 dB(A) baseline (KM1 prototype, without noise-reducing measures) - Per-kite buffer 430 m geo-fence - Kite at minimum permitted position (kite envelope towards dwelling, clipped by 430 m buffer) - 24-hour operation, no Lden advantage - Lp contribution from each station based on actual distance to dwelling

Contribution from each station (baseline Lw=105, clipped to 430 m buffer):

Station Lp at Nordhassel Lp at Råstad
A 33.2 dB 41.2 dB
B 33.6 dB 37.9 dB
C 34.8 dB 42.2 dB
D 33.1 dB 34.8 dB
E 36.0 dB 43.7 dB
F 36.9 dB 43.7 dB
G 35.5 dB 38.3 dB
H 38.4 dB 40.6 dB
I 35.1 dB 35.5 dB
J 38.3 dB 37.6 dB
K 40.4 dB 39.3 dB
L 42.9 dB 36.4 dB
M 42.7 dB 37.2 dB
N 43.7 dB 35.3 dB
O 43.7 dB 33.7 dB

(Stations in bold are buffer-limited to 430 m from the relevant dwelling.)

Logarithmic sum of contributions:

Scenario Lp Nordhassel Lp Råstad
15 active (full daytime operation, baseline Lw=105) 51.3 dB 51.4 dB
12 active (M, N, O off - night period) 48.4 dB 51.0 dB
12 active + nearest-to-Nordhassel off (L) at northerly wind 47.0 dB -
12 active + nearest-to-Råstad off (E) at southerly wind - 50.1 dB

Even with night shutdown of M, N, O and selective shutdown of the nearest station at critical wind direction, Lp without Bouman measures still lies 2-5 dB above the threshold value 45 dB(A). This is due to several stations in the same distance group (~770-1100 m) each contributing significantly.

With KM2 designed for low noise (Bouman measures, Lw_kite = 95 dB, -10 dB):

Scenario Lp Nordhassel Lp Råstad
15 active 41.3 dB 41.4 dB
12 active (M, N, O off) 38.4 dB 41.0 dB
12 active + nearest off (L or E respectively) at critical wind direction 37.0 dB 40.1 dB

With KM2 fully optimised (Lw_kite = 90 dB, -15 dB - Kitemill's target):

Scenario Lp Nordhassel Lp Råstad
12 active + nearest off 32.0 dB 35.1 dB

Conclusion:

These calculations are conservative: they use spherical sound propagation without air absorption (favourable for high-frequency AWE noise), assume maximum kite position towards the dwelling (geo-fence boundary), and include no terrain or vegetation attenuation. Actual values are likely to be lower.

11.4.6 Dwelling and building analysis

Threshold value (Lden) Scenario A (WITHOUT restriction, worst case) Scenario B (WITH geo-fence 400 m)
≥ 50 dB(A) 93 buildings 0 buildings
≥ 45 dB(A) (T-1442) 379 buildings 61 buildings
≥ 40 dB(A) 877 buildings 556 buildings
≥ 35 dB(A) 1,112 buildings 1,098 buildings

Note on building types: The table counts all OSM-registered buildings, including airport buildings (hangars, technical buildings) and outbuildings outside the airport's fence. Airport buildings are not "noise-sensitive built environment" pursuant to T-1442/2021 and are not dwellings. It is primarily the dwellings outside the airport that are relevant for assessment against the threshold value.

Sensitivity analysis for geofence radius:

Geofence radius Buildings ≥ 45 dB(A)
200 m 1 (probably airport building)
250 m 9
300 m 22
350 m 37
400 m 61
Without geofence (800 m tether) 379

To ensure Lden ≤ 45 dB(A) at all noise-sensitive dwellings, Kitemill commits to setting the geofence radius and operating pattern such that the requirement is satisfied. Final parameter setting is based on the measurement programme (cf. section 11.7) after commissioning.

11.4.7 Uncertainty

The total confidence interval is approx. ±8 dB. The uncertainty is due to: - Decomposition of the Bouman measurement into kite vs winch contribution (±3 dB) - Scaling from 30 kW test system to 100 kW production system (±3 dB) - Simplified propagation model without terrain shielding and air absorption (±2 dB) - Summation of 15 systems depending on final placement and operating pattern - The model uses worst-case kite position within the envelope; actual Lden will be lower because the kite is only part of the time in the worst position relative to each individual receiver

11.5 Relationship to ISO 9613-2 and choice of simplified model

NVE's usual practice and the Norwegian Environment Agency's guidance M-128 refer to ISO 9613-2 for detailed calculation of outdoor noise propagation at wind power plants. For NAWEP, it has been chosen not to carry out a full ISO 9613-2 calculation at the time of application, with the following justification:

  1. Temporary pilot and demonstration project: NAWEP's main purpose is to generate knowledge about environmental aspects of airborne wind power, including noise, through operation of an actual production system. An ISO 9613-2 calculation conducted on the basis of a test system with different power and geometry (KM1 30 kW) will not provide higher credibility than the scaling-based assessment in 11.4.

  2. Source data lacking for production system: ISO 9613-2 requires source noise data (Lwa) in accordance with IEC 61400-11 or equivalent for production turbines. Such data does not exist for the KM2 system, as NAWEP is the first installation at production scale. Data will be generated in the start-up phase and published (cf. 11.7).

  3. Proportionality: EIA Regulations § 17 provides that the content and scope of the impact assessment shall be adapted to the relevant project. With installed capacity 1.2 MW and a simplified assessment showing zero dwellings within the threshold value Lden 45 dB(A), an ISO 9613-2 calculation of hypothetical quality at the time of application is not proportionate.

  4. NVE practice for pilot projects: NVE's guidance for pilot and demonstration projects accepts adapted documentation level when license conditions ensure follow-up of knowledge gaps.

11.6 Comparison with conventional wind power

The dominant frequency from AWE systems lies in the range 1,500-2,000 Hz. This is substantially higher than conventional wind turbines, which typically generate low-frequency sound in the range 100-500 Hz.

This difference has great practical importance: high-frequency sound is attenuated substantially faster with distance than low-frequency sound due to air absorption that increases with frequency.

Parameter Conventional wind power AWE (Airborne wind)
Main source Blade passage, gearbox Tether vibrations + trailing edge
Typical frequency 100-500 Hz (low frequency) 1,500-2,000 Hz (high frequency)
Amplitude modulation "Swoosh" sound Continuous tone
Attenuation with distance Low (low frequency carries far) High (air absorption)

11.7 Mitigation strategy for compliance with Lden 45 dB(A)

11.7.0 Comparison with known sound sources

So that the reader can put the figures in section 11.4 in perspective, the table below gives typical dB(A) levels from familiar sources. These are approximate values (vary with distance and conditions):

Sound pressure level Example source
20 dB(A) Whisper, quiet bedroom at night
30 dB(A) Quiet library, low-voiced conversation in adjacent room
40 dB(A) Refrigerator humming in next room, quiet office
45 dB(A) T-1442/2021 threshold value for outdoor noise at dwelling (Lden)
45 dB(A) Light rain, birdsong, fan in adjacent room
50 dB(A) Normal conversation at 5 m distance, light traffic at distance
55 dB(A) Ordinary conversation distance, open-plan office
60 dB(A) Dishwasher, normal office noise
65 dB(A) Tumble dryer, light city traffic
70 dB(A) Vacuum cleaner, medium-density traffic
80 dB(A) City traffic at 10 m, loud music

NAWEP's objective is for Lden at the nearest dwelling (Nordhassel, Råstad) to be kept below 45 dB(A) - comparable with a refrigerator humming in a next room or birdsong.

11.7.1 Mitigation strategy

Kitemill applies a four-step mitigation strategy to ensure that the noise level at the nearest dwelling complies with T-1442/2021:

Step 1 - KM2 designed for low acoustic emission (prevention in design):

The KM1 prototype used for Bouman's noise measurements (2023) had several design weaknesses and was not optimised for low noise emission - acoustics was not an explicit design parameter. KM2 is a wholly new generation in which acoustic performance is included as an integrated design parameter from the outset. Specific work areas:

Expected combined effect: -10 to -15 dB on Lw_kite compared with KM1 baseline. This is Kitemill's primary and most effective measure for noise reduction. The final value is documented through source noise measurement in accordance with IEC 61400-11 after commissioning.

Step 2 - Operational optimisation (continuous research):

Kitemill will continue operational research throughout the pilot period. Operating parameters that affect acoustic emission and that will be optimised:

These parameters are optimised iteratively; the results are reported as part of the knowledge building in the pilot project.

Step 3 - Selective operational shutdown (last technical resort):

If steps 1-2 do not alone achieve sufficient margin against Lden 45 dB(A), individual systems will be taken out of operation. Acoustics has a central property that makes this effective:

Shutdown of the nearest system gives substantially larger reduction than shutdown of a more distant system.

Logarithmic summation entails that the nearest source dominates the receiver's sound level. Lp at a dwelling depends on 20·log10(r) of distance - halving the distance gives 6 dB higher contribution. When the nearest source is removed, Lp_total can fall 3-5 dB even though 14 of 15 stations remain in operation.

Fixed night shutdown for M, N and O: Stations M, N and O lie south in the cluster and are among the nearest to the settlement at Nordhassel (765-850 m). These three stations are not operated at night (T-1442 night period, 23:00-07:00) as a binding commitment in the license conditions. This gives an immediate reduction in nightly Lden contributions without major production loss (the wind is often lower at night).

A similar principle applies for other stations and other time periods, based on measured level at the affected dwelling.

Step 4 - Neighbour involvement and dialogue:

Kitemill establishes direct and continuous dialogue with neighbours in Nordhassel and Råstad regarding perceived noise level. If neighbours experience noise as a burden - even though Lden formally remains below 45 dB(A) - Kitemill will jointly with the affected neighbour find solutions that are appropriate. Possible measures from dialogue:

Neighbour involvement is handled through a formal neighbour forum with regular meetings (at least annually, more frequently at start-up) and an open channel of communication. This is not a minimum requirement but a genuine commitment to being a good neighbour.

11.7.2 Expected effect of the strategy

Calculated baseline in section 11.4 (KM2 without noise-reducing measures, 15 stations in operation, 24-hour operation): summed Lp ≈ 47-48 dB(A) at the nearest dwelling.

Measure Expected change Resulting Lp at nearest dwelling
Baseline (without measures) - 47-48 dB(A)
+ Step 1: KM2 designed for -10 dB Lw -10 dB 37-38 dB(A)
+ Step 1: KM2 designed for -15 dB Lw (target) -15 dB 32-33 dB(A)
+ Step 3 night shutdown M/N/O -3 to -5 dB at night Further reduction at night

Conclusion: With step 1 (KM2 design optimisation -10 dB), Lden 45 dB(A) is observed with a comfortable margin of 7-12 dB at the nearest dwelling. Steps 2-4 provide robustness, flexibility and neighbour involvement. Final documentation is provided through the measurement programme (section 11.7.3).

11.7.3 Commitment: measurement and iterative adjustment

Kitemill commits to the following measurement and adjustment regime that ensures Lden 45 dB(A) is observed at the nearest noise-sensitive built environment:

  1. Source noise measurement (baseline): Acoustic measurement of the KM2 system in accordance with IEC 61400-11 or equivalent standard within 6 months of commissioning. Measurements are carried out with gradual ramp-up of the number of systems in operation (1, 3, 5, 8, 15) to verify the logarithmic sum model and isolate the contribution from each sound source.

  2. Immission measurement at settlements: Fixed measurement points are established at the nearest dwelling in Nordhassel (south of the runway, approx. 765 m from station N) and Råstad (north/north-east, approx. 776 m from station F), as well as other representative positions. Measurements are carried out continuously in representative periods (minimum 1 week per quarter in the first year of operation), and cover different wind directions, operating conditions and time periods (day/evening/night).

  3. ISO 9613-2 propagation calculation: Complete calculation is updated with measured source noise and reported to NVE within 12 months of commissioning of phase 1.

  4. Threshold value compliance: The plant is operated such that Lden 45 dB(A) outdoors at the facade of noise-sensitive built environment is not exceeded, cf. T-1442/2021. This is a binding commitment regardless of measure combination.

  5. Binding operating commitments: - Stations M, N and O are not operated during the night period (23:00-07:00). - Per-kite buffer 430 m around the nearest dwelling (geo-fence) preventing any kite from coming closer than 430 m from a dwelling under any operating conditions whatsoever.

  6. Iterative adjustment in case of exceedance or warning: In the event of measured exceedance, or if measured values show a trend towards exceedance, further measures are implemented within 6 months. Hierarchy of measures: - Operational optimisation (step 2): speed, altitude, flight pattern - Extended selective operational shutdown (step 3): more stations, longer time windows - Modification of kite/tether design (reinforced step 1) - Neighbour negotiation regarding operational adjustments (step 4)

  7. Full operational shutdown as last resort: If combined measures do not provide documented compliance, operation of affected stations is suspended until sufficient measures are implemented.

  8. Annual reporting to NVE: Acoustic status, measured values, any exceedances, measures implemented and neighbour forum activity are reported annually as part of operating reporting. The pilot project shall be transparent: raw data from the measurement programme are made available to NVE and research institutions.

Kitemill regards the measurement programme and neighbour involvement not as burdens but as core values of the pilot license: actual operating data and perceived neighbourhood effect from the first commercial AWE plant are necessary knowledge for the owner, neighbours, NVE and future regulation.

11.8 Knowledge value for future regulation

As the first installation at production scale, NAWEP's measurement programme will provide the authorities (NVE, the Norwegian Environment Agency, municipalities) with a documented professional basis for future AWE licenses and for any revision of T-1442/2021's treatment of airborne power sources.

References: - Bouman, N. (2023). Aeroacoustics of Airborne Wind Energy Systems. MSc thesis, TU Delft. - Norwegian Ministry of Climate and Environment (2021). T-1442/2021 Guideline for the treatment of noise in land-use planning. - IEC 61400-11. Wind turbines - Part 11: Acoustic noise measurement techniques.


12. SHADOW FLICKER

Note: NVE's application template addresses shadow flicker from rotating turbine blades. For AWE systems, this issue is substantially different, as there are no rotating components in the traditional sense.

12.1 Assessment for AWE

The AWE system has no rotating blades in the traditional sense. The kite moves in a circular motion at 200-400 metres altitude.

Shadow flicker from AWE: - The kite is small (17 m wingspan) compared with turbine blades - High operating altitude gives diffuse, not focused shadow - Movement is continuous, not flickering as with rotor blades - Assessed as negligible compared with conventional wind power


13. OUTDOOR RECREATION AND OUTFIELD USE

13.1 Use of the area

The Lista area is used for: - Birdwatching (especially at Slevdalsvannet and wetlands) - Beach activity (Lista beaches) - Cultural-historical experiences (WW2 plants, rock carvings) - Agriculture

13.2 Accessibility of the plan area

The airport area is partly closed off and not generally accessible for outdoor recreation. The project does not affect: - Hiking trails - Beach areas - Birdwatching localities (outside the plan area)

13.3 Nesheimsvatnet

Nesheimsvatnet nature reserve lies approx. 1.4 km south-east of the nearest planned station (station O).

Map showing station locations in relation to Nesheimsvatnet nature reserve Figure 13.1: Overview map showing the planned station locations (A-O) in relation to Nesheimsvatnet nature reserve (green area). The nearest station (O) lies approx. 1.4 km from the reserve boundary.

Status of the protected area: - Name: Nesheimsvatnet nature reserve - Type of protection: Nature reserve - Date of protection: Protected as part of the Lista wetland system - Management authority: County Governor of Agder

Assessment: - The plan area does not directly affect Nesheimsvatnet nature reserve - The distance from the nearest station (O) to the reserve boundary is approx. 1.4 km - AWE operation in the airspace above the airport will not directly affect wetland functions - Birds migrating between Nesheimsvatnet and other wetlands (Slevdalsvannet, Lista wetland system) are monitored as part of the bird monitoring programme

Conclusion: The project does not affect the Nesheimsvatnet area directly. The distance from the nearest station to the reserve boundary is assessed as sufficient to avoid direct disturbance of wetland functions. Bird activity in the corridor between the wetlands is followed up through the monitoring programme.


14. CULTURAL HERITAGE AND CULTURAL ENVIRONMENT

14.1 WW2 cultural heritage

Lista Airport has extensive WW2 history:

Cultural heritage Status Location
Runway and infrastructure from 1942 Protected Plan area
Hangar 45 (Festung Lista museum) Protected Plan area
Nordberg Fort Protected by the Directorate for Cultural Heritage > 3 km north
Marka battery Protected Plan area

14.2 Automatically protected cultural heritage

Rock carving site at Penne: - Approx. 3,000 years old (Bronze Age) - 22 boats, two footprints, approx. 70 cup marks - Location: North of the plan area, in West Lista cultural landscape - Status: Automatically protected (older than 1537)

Hervoll Mill: - Two old mill houses - Location: East of Nordberg Fort - Functions as a museum

14.3 Cultural landscape

West Lista selected cultural landscape: - National status (KULA register) - Stone walls and agricultural landscape - Biodiversity and cultural heritage - Norway's highest density of ancient monuments

Lista beaches landscape protection area (1987): - 8,012.5 daa - Distinctive natural and cultural landscape - Geological, botanical and cultural-historical qualities

14.4 Festung Lista - historical context

Lista Airport was during WW2 part of "Festung Lista" - an extensive German military complex: - Approx. 300 buildings erected by the occupying power - Lundebanen (narrow-gauge railway to Lundevågen, opened 1943) - Marka battery (field guns with 22 km range) - Approx. 10,000 workers engaged in construction

Museums in the area: - Festung Lista Hangar Museum (Hangar 45) - Nordberg Fort (Directorate for Cultural Heritage protected, museum since 2009)

14.5 Assessment

The AWE plant: - Does not directly affect ground-based cultural heritage - No excavation or construction work near protected objects - The ground stations are placed on existing asphalt surface - Visual impact on the cultural landscape is assessed in section 10 - Operation in the airspace does not affect physical cultural heritage


15. PUBLIC HEALTH AND LIVING ENVIRONMENT

15.1 Nearest settlements

Area Distance from nearest ground station Comment
Nordhassel (individual dwellings) approx. 770 m (from station N) South of runway
Råstad (individual dwellings) approx. 776 m (from station F) North/north-east of runway
Lista population centre approx. 1,400 m (from station D) West of runway
Borhaug population centre approx. 4,000 m (from station D) Further west

15.2 Overall assessment

Based on: - Noise (section 11): Within threshold values - Visual impact (section 10): Moderate, reversible - Shadow flicker (section 12): Negligible - Outdoor recreation (section 13): Minimal impact

Overall assessment: Acceptable impact on public health and living environment.

15.3 Electronic communications (ekom)

An assessment of NAWEP's impact on electronic communications has been carried out in accordance with Nkom (Norwegian Communications Authority) and NVE's current guidelines for safeguarding electronic communications in wind power development (Nkom's revised guidelines effective from 1 October 2025).

15.3.1 Identified ekom actors and services in the area

The mapping of ekom infrastructure around Lista has been carried out through Nkom's web service Finnsenderen.no. The following categories have been identified as potentially relevant:

During the consultation phase of the licensing process, Kitemill will make a formal enquiry to Norkring, the principal mobile network operators and Avinor in order to clarify any specific radio link routes and frequency allocations crossing the operating area, so that any substantiation of interference can be documented on a concrete basis.

15.3.2 Assessment of harmful interference from NAWEP

The risk of harmful interference to ekom networks from NAWEP is assessed as substantially lower than for conventional wind turbines for the following reasons:

Kitemill's command and control link (C2 link) operates in a licence-exempt SRD (Short Range Devices) sub-band under Nkom's general authorisations, harmonised with ETSI EN 300 220 and the European SRD allocation. The band is reserved for short-range telemetry and does not overlap with mobile networks, digital terrestrial broadcast (DVB-T2) or aviation VHF communications. Actual transmit power is substantially below the regulatory ceiling, and communication takes place only locally between kite and ground station. Operational airtime is within SRD framework limits; Kitemill verifies compliance through internal operational logs documented in the SQIS system.

15.3.3 Commitments and mitigation measures

Kitemill commits to:

It is proposed that the license decision include Nkom/NVE's standard conditions on mitigation measures in case of harmful interference.

15.4 Water and ground pollution

15.4.1 Emission sources

NAWEP has limited potential for water and ground pollution:

15.4.2 Risk assessment

The Lista area has adjacent wetland areas (Slevdalsvannet, Nesheimsvatnet - Ramsar). Risk assessment:

15.4.3 Mitigation measures

The consequence for water and ground is assessed as low, given normal operation and established emergency preparedness routines.


16. CO-USE AND COORDINATION

16.1 Current users of Farsund Airport

Lista/Farsund Airport is a multi-use arena. The following actors regularly use the airport area:

16.2 Coordination principle

Established aviation, military activity and rescue services have priority over AWE operation. Kitemill's systems are designed for rapid landing, and operation is adapted to other activity.

16.3 Coordination measures

The following measures will be implemented in cooperation with Farsund Lufthavn AS:

  1. Time-slot-based planning: Operating periods are organised in blocks that can be reserved and cancelled with set deadlines, so that all parties have predictability.
  2. Dialogue and input meetings: Regular meetings with the airport's other users and the local community to adapt operating and operational pattern.
  3. Communication tools: Telephony and aviation radio are used for direct coordination, in line with established practice at airports.

16.4 Private airstrip

There is a private landing strip in the vicinity of station L. Kitemill is aware of this and will observe applicable rules for obstacle limitation surfaces and altitude restrictions also for this airstrip.

16.5 U-space airspace organisation

Kitemill plans to implement the European U-space regulatory framework (EU Regulation 2021/664) for the organisation of airspace activity at Farsund Airport. This entails the use of a USSP (U-space Service Provider), for example AirDodge, for coordination between AWE operation and other aviation activity. The experience from this implementation may form the basis for future airspace organisation at other AWE plants in Norway.


17. NATURAL HAZARDS AND SAFETY

17.1 Introduction

This chapter covers NVE's feedback point 3 (risk assessment) and point 4.9 (Norwegian Armed Forces), as well as points 4.3 and 4.8 (safety zones and marking). The content is structured as follows:

17.2 Safety and risk management (SORA regime)

17.2.1 Regulatory framework and pathway

NAWEP's air operations are regulated by EU Regulation 2019/947, implemented in Norway through regulation 2024-11-01-2777 (BSL A 7-2 on unmanned aviation, Norwegian regulation on unmanned aviation, implementing EU 2019/947), and are conducted in accordance with the SORA methodology (Specific Operations Risk Assessment). Kitemill has established a documented regulatory pathway through the gradual extension of operating permits for the KM1 system:

Milestone Date Reference Type of operation SAIL level
First VLOS operating permit KM1 12.01.2023 22/02391-20 / NOR.OA.000141 VLOS, Day only SAIL II
Updated VLOS operating permit KM1 20.01.2025 22/02391-46 VLOS SAIL II
BVLOS operating permit KM1 16.10.2025 (valid until 16.10.2027) 22/02391-68 / NOR-OAT-000294/000 BVLOS SAIL II
VLOS Training UAVs 18.12.2025 22/02391-77 VLOS SAIL II

The BVLOS approval from October 2025 is the most relevant for the NAWEP project and demonstrates that Kitemill's operating pattern is approved for continuous operation without pilot line-of-sight, and that CAA-N has accepted SAIL II risk level (Sparsely populated, ARC-a operationally / ARC-c adjacent, M1 and ERP medium) and operations at Lista Airport (the D257 area, upper limit 4,000 ft AMSL = 1,220 m).

17.2.2 Containment for NAWEP

NAWEP's containment (SORA Basic, cf. point 4.13 of the BVLOS authorisation) is established through four layers, documented in Kitemill's Operations Manual QP-OPS-001 (the BVLOS authorisation NOR-OAT-000294/000 of 16.10.2025 refers to rev. 3.0; the current version is rev. 4.0, CAA-approved January 2026):

1. Tether tethering and operating volume

The tether system physically restricts the kite's movement to a hemisphere around the ground station. The ground impact zone in case of total failure is inherently limited to approx. a 1:1 ratio between operating altitude and horizontal distance. The operating volume consists of a flight volume (in which the kite is to operate) and a contingency volume (the volume reserved for recovery upon control deviation).

2. Ground risk classification

In accordance with Kitemill's BVLOS operating permit (NOR-OAT-000294/000, 16.10.2025), the operational area is classified as Controlled ground area and sparsely populated areas (combination), and the adjacent area as sparsely populated. The kite operates primarily within Lista Airport's secured industrial area, but the operating volume may also extend beyond the airport fence in accordance with the operating permit. The ground risk buffer - the area in which the kite could potentially fall - lies within a sparsely populated agricultural and forest area without residential buildings, confirmed through population data (cf. fig. 4.9 and 4.10 in section 4.9).

3. Air risk buffer - EN D257

Kitemill has established danger area EN D257 as an airspace barrier. The area is announced through NOTAM at least one week before operations. It defines separation from other civil aviation and has an upper limit of 4,000 ft AMSL (1,220 m). The vertical extent of the danger area to 1,220 m constitutes a regulatory reserve against other aviation; the maximum operating altitude for each kite unit is 500 m above ground (cf. section 4.6), and the operational volume therefore uses only a smaller part of the reserved airspace.

4. Contingency procedures and automatic flight termination

OM rev. 4.0 chapter 5.2 specifies dedicated contingency procedures for each identified failure mode. NAWEP is a BVLOS operation, and the following applies:

The return-to-home function was extended and demonstrated in February 2026. The function fulfils the regulatory flight termination requirement by bringing the kite back to the ground station within the operating volume, and at the same time provides operational value through intact landing of the aircraft.

Together, these four layers constitute NAWEP's containment architecture and satisfy the SORA Basic containment requirements. Enhanced containment may be considered in future updates of the SORA documentation based on actual operational data, together with CAA-N.

17.2.3 NAWEP as further development (KM2)

The NAWEP project builds on the KM2 system, a further development of KM1. KM2 differs from KM1 in the following respects:

NAWEP therefore requires an updated SORA and a new operating permit from CAA-N for the KM2 operation. The SORA update is prepared and submitted to CAA-N ahead of phase 2 of project execution, in parallel with financing and engineering, so that the updated operating permit is in place before installation of the KM2 systems begins. The transition from SORA V2.0 to SORA V2.5 (JARUS 2024, implemented 2026) will be part of this process.

Kitemill's track record of three completed operating permits over 3 years (VLOS, BVLOS, Training UAVs), together with active dialogue with CAA-N, makes it likely that a corresponding approval will be obtained for the KM2 operation before commissioning of phase 1 (planned 2027).

17.2.4 Fact box: SORA 2.5 and NAWEP/KM2

FACT BOX: SORA 2.5 and NAWEP/KM2

What is SORA 2.5?

SORA is the methodology the EU uses to approve operations with unmanned aircraft in the specific category. Version 2.5 was published by JARUS in November 2024 and gradually replaces version 2.0 through 2026.

Most important changes from SORA 2.0 to 2.5:

Area SORA 2.0 SORA 2.5
Intrinsic GRC table 10 scenarios New iGRC table with explicit numerical population density intervals
Containment Basic / Enhanced qualitative Basic / Enhanced with detailed technical and assurance requirements
Anchored UAS General provisions Specifically addressed with its own pathway
OSO structure 24 OSOs Restructured into clearer groups

KM2/NAWEP adaptation: Compensated through tether tethering (inherent ground risk buffer limitation 1:1), operational restrictions and well-established procedural structure. Kitemill has active dialogue with CAA-N's section for unmanned aviation (contact: August Holte, flight operations inspector).

17.2.5 Safety around ground stations

The current wording on "safety zones around ground stations" is corrected here. Safety around the ground stations is ensured through operational regime, not through geometric circles:

17.2.6 Margin to densely populated area

The population map (fig. 4.9) shows that the nearest "populated"-classified area (Borhaug) lies approx. 5 km from the plan area. Vanse and Farsund lie 6-7 km east. These distances are substantially greater than the relevant Ground Risk Buffer.

17.3 Experience and systematic learning from the development period

17.3.1 Principle for Kitemill's safety culture

Kitemill has, since 2008, worked according to the principle that every incident shall provide a basis for concrete improvement. This is operationalised through:

17.3.2 Earlier incidents and follow-up

During the development period 2015-2026, Kitemill has had a small number of unplanned landings of test aircraft at the Lista test plant. All incidents have occurred within classified and controlled ground area, and none have resulted in personal injury or damage to third-party infrastructure.

Each incident has been analysed for root cause and has provided the basis for concrete technical, operational and organisational measures. A full incident log and risk assessment is documented in Appendix 08 - Risk assessment NAWEP.

17.3.3 Learning translated into measures

Incident category (learning from) Specific measure introduced
Loss of control upon transition automatic↔manual mode Redundant control system. Explicit confirmation upon critical mode changes. Revised pilot procedure in OM.
Loss of control with radio equipment Revised failsafe requirements for transmission equipment. Automatic safe state in the event of radio loss.
Energy shortage during prolonged flight Redundant battery and charge monitoring. Operational operating time restrictions. Automatic return-to-base on low reserve.
Uncontrolled fly-away (soft kite system) Tether load monitoring with deviation detection. Automatic activation of contingency procedures upon deviation from the contingency volume.
Unstable flight in marginal wind Low-wind algorithm and turbulence prediction developed in 2026.
Operational consolidation during BVLOS scale-up Extended pilot training for BVLOS. Control room monitoring. Revised Standard Operating Procedures. CAA dialogue resulted in BVLOS operating permit (NOR-OAT-000294/000, 16.10.2025).
Classification and handling of ground area Pre-flight checklist for ground area. Permanent danger area EN D257 established. Observer role for endurance operations over controlled ground area.
Documentation and reporting routines Operations Manual updated to rev. 4.0 (CAA-approved). Systematic QHSE reporting.
Pilot ergonomics and fatigue Operating time restrictions per pilot. Rotation between control room pilot and field team. IMSAFE assessment at each shift.

17.3.4 Maturation over time

17.3.5 NAWEP: from development to permanent operation

The transition from development phase to NAWEP's commercial operation further strengthens the safety regime:

17.3.6 Risk register NAWEP

Pursuant to NVE's feedback (18 March 2026, point 3), an explicit risk register has been prepared for both unintentional and intentional incidents. The table below is a summary from Appendix 08 (Risk assessment NAWEP, prepared by CTO Marius Dyrset). Probability and consequence classes follow the DSB risk matrix (Low / Medium / High). The risk class is the resultant of P x C, where P = probability and C = consequence.

# Incident P C Risk class Mitigation measures
1 Unplanned landing of kite (loss of control or battery loss) Low Low Low Containment architecture (cf. section 17.2.5); automatic flight termination with return-to-home; geo-fence 400 m; fire preparedness in case of battery damage (cf. section 15.4); observer on duty during operation
2 Tether failure (line break) Very low Medium Low Certified HMPE tether with 4x safety factor; daily pre-flight inspection; continuous load monitoring; automatic safe state in case of abnormal load history
3 Tether crossing (between KM2 systems or between kite and other aircraft) Low High Medium Geo-fence at 400 m sphere isolates each station; separation distance 800-1,000 m between stations; BVLOS procedures for simultaneous operation; danger area EN D257 separates NAWEP airspace from other civil aviation; ongoing coordination with the Norwegian Armed Forces (cf. section 17.4)
4 Power outage (at ground station or from distribution grid) Medium Low Low UPS battery backup on control system; automatic safe state on power loss; pre-planned landing within 5 minutes on reserve battery; redundant communication (Direct + network C2 link, cf. BVLOS authorisation point 4.7)
5 Fire (in ground station, kite, battery or transformer) Low Medium Low Fire/smoke detectors in ground station; oil collection trays beneath transformers; battery management system with thermal runaway detection; fire preparedness plan in OM rev. 4.0 chapter 7; extinguishers on site; alarm to the 110 emergency centre
6 Extreme weather (storm, lightning, icing, freezing rain) Medium (seasonal) Medium Medium Real-time weather monitoring with automatic departure at cut-out (24 m/s); thunder/lightning detection with automatic retrieval and landing; ice-warning mode with early return on frost forecasts; extreme weather procedures in OM
7 Technical failure (sensor, actuator, communication, generator) Medium per component Low Low Redundant sensor/actuator architecture (2-out-of-3 voting where relevant); automatic degraded mode on single failure; real-time health monitoring with automatic landing on critical failure; planned maintenance pursuant to NS 8407
8 Total loss of kite with descent into controlled ground area Very low Medium (local damage to airport infrastructure) Low Four-layer containment architecture (cf. section 17.2.5); automatic flight termination system; geo-fence ensures fall within classified ground area; no third-party infrastructure in the contingency volume; pre-flight inspection of the ground area
9 Intentional incidents (sabotage, cyber attack, physical intrusion, hostile drone) Low High Medium Access control to Lista Airport's secured industrial area with perimeter fence and CCTV; encrypted C2 link with authentication and integrity check; redundant command/control channel; continuous security monitoring; cooperation with NSM and the Norwegian Armed Forces on airspace surveillance (cf. section 17.4); security protocol in OM rev. 4.0

The risk matrix is aligned with Kitemill's CAA-N approved SORA V2.0 assessment (BVLOS operating permit NOR-OAT-000294/000, SAIL II), which identifies ARC-a as the residual airspace risk in the operational volume and ARC-c in the adjacent volume, with M1 and ERP at medium level (cf. authorisation points 3.8 and 3.10).

Conclusion: After mitigation measures, all identified incidents lie at risk class Low or Medium. No risk is classified as High. Incidents in the Medium class (tether crossing, extreme weather, intentional incidents) have dedicated procedures in Operations Manual rev. 4.0 and are subject to continuous follow-up in Kitemill's QHSE system.

17.4 The Norwegian Armed Forces and coordination in the airspace

17.4.1 Existing dialogue and coordination

Through 2025-2026, Kitemill has established an active and constructive dialogue with the Norwegian Armed Forces' Drone Services, which also has an operational presence at Lista. The dialogue covers coordination of simultaneous use of the airspace, exchange of information about operational time windows, and assessment of possible technical and operational integration points.

The Norwegian Armed Forces have applied for a restricted area which in practice gives the Armed Forces priority access to the air volume. Neither Kitemill nor the Armed Forces consider this problematic, as use can be coordinated, and large parts of operations can be conducted simultaneously within dedicated time windows or through dynamic coordination.

Status of formal coordination: The dialogue is, as of April 2026, in an operational phase. Formal written statements from the Norwegian Armed Forces / Norwegian Defence Estates Agency will be obtained and documented as part of NVE's consultation process, so that the consultation responses are available at the same time as NVE processes the application. Correspondence from the Norwegian Armed Forces' Drone Services with relevance to co-use coordination will be forwarded as a consultation input when available.

17.4.2 U-space as a future coordination mechanism

Kitemill and the Norwegian Armed Forces have expressed a common interest in considering U-space as a relevant coordination platform for unmanned aviation in the area. U-space is the EU's regulatory framework for safe and efficient operation of a larger number of unmanned aircraft in defined airspace, and may provide real-time coordination between civil and military operations in a robust manner.

17.4.3 The Armed Forces' overarching prerogatives

The NAWEP project will respect that the Armed Forces in all cases safeguard their obligations relating to emergency preparedness and protection of critical societal functions. This includes the Armed Forces' need for Control and Reporting (K&V) in the airspace, the Armed Forces' ability to assert national sovereignty, as well as emergency preparedness considerations and national security.

Kitemill expects that the Armed Forces, as in earlier consultation processes, will focus on ensuring that new plants in the airspace do not reduce the Armed Forces' capacities in control, reporting and communications. NAWEP's technical and operational solutions have been developed with this consideration in mind.

17.4.4 Societal benefit through cooperation

Through 2025-2026, Kitemill has been in dialogue with various branches of the Armed Forces about potential cooperation where Kitemill's airborne wind technology can support the Armed Forces' needs. The cooperation has two main dimensions:

A) Capabilities from continuous airspace presence (ISR and communications):

B) Portable renewable energy production:

AWE represents, for the first time, a renewable technology that can be moved. A KM2 plant, of which NAWEP will test multiple instances, alone produces energy equivalent to 12-15 truckloads of diesel annually. This provides unique operational applications for the Armed Forces:

17.4.5 Expected assessment

Kitemill assumes that the Armed Forces, when assessing NAWEP, will take necessary reservations regarding long-term emergency preparedness considerations, will use the knowledge built up in NAWEP as a basis for future operational decisions, and will initially assess that the advantages of the project are greater than the disadvantages, based on already established dialogue and the documented coordination basis.

17.5 CAA-N's assessment

CAA-N has, in a consultation statement to Farsund municipality (May 2025), stated:

"CAA-N is generally positive towards technological development in the drone industry, and has no objections to using Lista Airport for testing purposes as long as air and ground risk are addressed through existing and any new approvals."

CAA-N has further recommended that Kitemill apply for new airspace restrictions around the operating area to safeguard the safety of other air traffic at full-scale demonstration plant. Kitemill will follow this recommendation through the SORA update for KM2 and dialogue with CAA-N.

17.6 Ice throw

Note: For conventional wind power, ice throw from rotor blades constitutes a documented risk. For AWE systems, this issue is substantially different.

In icing conditions, the AWE system will: - Automatically land (cannot fly with ice on the wing) - Not operate under icing conditions - Risk of ice throw is assessed as negligible

17.7 Flood and landslide hazard

The plan area lies on flat ground at Lista Airport. The area has varied surface - asphalt runway, taxiways and ring roads with concrete surface, as well as cultivated land where the ground stations are placed. The risk of landslides is assessed as negligible due to the flat topography.

For flood risk, station locations will be assessed against the 20-year flood. Where local ground conditions so indicate, the terrain will be raised with fill or drainage will be improved to secure the ground stations. The temporary nature of the project and container-based ground stations mean that the plants can be moved as needed.


18. CUMULATIVE IMPACT

18.1 Existing burden in the area

The Lista area already has: - Airport with air traffic - Agricultural activity - Tourism and outdoor recreation - Existing infrastructure

18.2 Cumulative effects

Factor Existing AWE contribution Combined
Noise Air traffic Low addition Acceptable
Visual Hangars, buildings Moderate Acceptable
Birds Air traffic, agriculture Monitored Addressed through monitoring programme

18.3 Other plans in the area

It is not known that there are other planned energy projects or larger development projects in the immediate vicinity of the plan area that would entail further cumulative burden. Solkraft Lista AS has plans for a solar cell installation at the airport area, and this project is coordinated with NAWEP through joint grid connection.


19. ZERO ALTERNATIVE

19.1 Definition

The zero alternative is the situation if the NAWEP project is not implemented.

19.2 Consequences of the zero alternative

Energy production and climate targets

If the project is not implemented, no renewable energy will be produced from AWE technology in Norway. At mature operation, the project may deliver up to 4.2 GWh annually to the regional grid (price area NO2), which in recent years has had higher power prices than other price areas in Norway (cf. section 2.4.1). Based on the EU Innovation Fund's calculation methodology (emission factor 0.15 tonnes CO2e/MWh), this corresponds to an annual greenhouse gas saving of about 630 tonnes CO2 equivalents at mature operation.

Norway has committed to a 55% emission reduction by 2030 and 70-75% by 2035. The Norwegian Energy Commission has identified a need for at least 40 TWh of new power production. Although NAWEP in isolation represents a limited volume, the project's primary climate contribution is to develop and document a technology which, with commercial scaling, can give a substantially larger contribution with lower resource use than conventional alternatives.

Knowledge building and biodiversity

Without NAWEP, no systematic knowledge will be built up regarding the interaction between AWE technology and Norwegian nature. The project is designed to generate data on bird activity, visual impact, noise and operational adaptations that will form the basis for knowledge-based management in any future roll-out of AWE in Norway. This knowledge cannot be replaced by experience from other countries, as local natural conditions and migratory routes are site-specific.

The existing burden on the plan area from air traffic and agriculture will continue unchanged regardless of the zero alternative.

Technology development and Norwegian industrial position

Through Kitemill, Norway has a significant position in the AWE sector internationally. The company is among the most established and active developers of airborne wind energy globally. If NAWEP is not implemented, this position may be weakened. Technology development will continue in other countries - Germany has already introduced a feed-in tariff for AWE, and several European actors are preparing demonstration plants. The EU has invested EUR 3.35 million in NAWEP through the Innovation Fund, and a failure to implement will reduce Norwegian influence on the technology's further development and future regulation.

Local value creation

The zero alternative entails that no jobs or R&D activity related to AWE are created at Lista. The airport's suitability as a location for renewable energy production and technology development will not be tested, and the region will miss out on associated business development and competence-based jobs.

19.3 Assessment

The zero alternative entails that the opportunities for climate transition, knowledge building, local value creation and Norwegian industrial position within an emerging technology will not be realised. The project's mitigation measures are designed to limit impact on biodiversity to a minimum, and the limited reduction in burden that the zero alternative entails must be weighed against the opportunities the project represents.

19.4 Quantitative balance: benefits and drawbacks against the zero alternative

In line with NVE's feedback (18.03.2026, point 2), this section presents a quantitative comparison of the project's benefits and drawbacks against the zero alternative (no development). The figures represent the expected operating point after commissioning (mature operation from 2029) and are based on Kitemill's own calculations, external tenders, EU Innovation Fund reporting and publicly available references.

19.4.1 Direct quantitative benefits

Topic Zero alternative NAWEP implemented Net benefit
Renewable energy production 0 GWh/year 4.2 GWh/year (1.2 MW × 3,500 full-load hours) +4.2 GWh/year — power equivalent to approx. 270 Norwegian households (15,500 kWh/year)
Greenhouse gas reduction (EU IF methodology) 0 tonnes CO2e/year 630 tonnes CO2e/year (0.15 t/MWh × 4.2 GWh) +630 t CO2e/year — equivalent to approx. 274 Norwegian passenger cars' annual emissions (2.3 t/car)
Permanent land use per MWh produced n/a 520 m² / 4,200 MWh/year = 0.12 m²/MWh Approx. 1/30 of conventional onshore wind power (typically 3-4 m²/MWh including roads and foundations)
Material consumption per MW installed n/a ~50 tonnes (kite + ground station + tether per 100 kW × 15) Substantially lower than conventional 1.2 MW HAWT (typically 200-400 tonnes including foundation). Kitemill estimate, to be verified through NAWEP
Reversibility at project end n/a 100 % reversible — no permanent concrete foundations or access roads Complete area restoration possible (cf. section 20.2.5)

19.4.2 Indirect quantitative benefits

Topic Zero alternative NAWEP implemented Net benefit
Secured EU/international funding 0 EUR EUR 3.35 million (EU Innovation Fund, NAWEP programme) + AWE-KM2 (Horizon Europe Grant 101189207) + AWETRAIN doctoral training network (MSCA Grant 101168734) + 3D-Circular (HaDEA Grant 101226256) EUR 3.35M+ directly to NAWEP, total EU funding for Kitemill approx. EUR 9-10M for Lista-related R&D
Local investments (CAPEX) 0 NOK 76-85 MNOK over the installation phase, of which approx. 3.4 MNOK directly to a local contractor (Grunnlink, Lista) for civil works 76-85 MNOK invested in the region 2026-2028, with a substantial share to local suppliers
Operating phase OPEX (annual) 0 NOK 3.5-5.0 MNOK/year (operations, R&D, bird monitoring, insurance, ground rent) 3.5-5 MNOK/year continuous regional activity over the 3+ year operating phase
Direct employment in operations 0 FTE 5-8 FTE at Kitemill (Lista + HQ Vågsbygd) Permanent R&D activity in the Lister region + indirect employment at Glitre Nett, Grunnlink and local service providers
Academic and industrial competence n/a Doctoral positions via the AWETRAIN network (NTNU/TU Delft); master's and bachelor's supervisors; technical field data to IEA Wind Task 48 Norway retains a competence base in an emerging sector; export volume for knowledge and IP
Data points for knowledge-based regulation 0 3+ years of continuous data on noise, bird behaviour, AWE performance under Norwegian conditions; public publication of key results Dataset available to NVE, the County Governor, municipalities and academia for future AWE applications

19.4.3 Strategic benefits (qualitative, but measurable through positioning)

19.4.4 Quantified drawbacks / costs (cf. chapters 8-17)

Topic Quantified impact Mitigation measures (cf. chapter 20)
Permanent land use approx. 520 m² (0.05 ha) within the airport's existing industrial area 100 % reversible; no new roads; no protected areas affected
Temporary land disturbance during construction approx. 7,700 m² (cable trenches, lay-down area, drilling pits) Restoration after construction; no permanent terrain interventions
Noise (Lden) at nearest dwelling < 45 dB(A) (below T-1442/2021 limit value) — Nordhassel approx. 770 m, Råstad approx. 776 m Bouman measures (-10 dB Lw_kite), night shutdown M/N/O 23-07, geofence 400 m, measurement programme 1 week/quarter year 1 (cf. section 11.7)
Visual impact Kites visible from approx. 3-5 km on a clear day; ground stations approx. 3 m high Reversible; only visible during operation; low visual signature compared to conventional towers (80-150 m)
Birds Potentially sensitive impact; expert assessment for 15 systems by Arnold Håland/NNI (cf. chapter 9) Phased ramp-up (1-3-15 systems over 3 years), shutdown during migration periods, continuous AI camera + manual monitoring, adaptation commitment upon notified incidents
Risk (undesired incidents) After mitigation: all 9 NVE-specified incidents classified Low or Medium; none High (cf. section 17.3.6 risk register) Four-layer containment architecture, automatic return-to-home, certified SAIL II BVLOS approval valid until 16.10.2027
Biodiversity (Slevdalsvannet, Nesheimsvatnet) Direct contact: 0. Indirect impact assessed as limited (distance 330 m and 1,400 m respectively from the nearest station) Monitoring programme documents actual indirect impact; adaptations committed upon any findings

19.4.5 Industrial scaling potential — from NAWEP pilot to European production

NAWEP is deliberately designed as a direct precursor to Kitemill's industrial scale-up. The company submitted on 23.04.2026 an application to the EU Innovation Fund 2025 (Clean Tech Manufacturing) for FJORD — the first vertically integrated AWE factory in Europe, with Lista as a candidate location (Letter of Intent from Venturos AS for industrial-zoned land at Lista, signed 21.04.2026).

Parameter (FJORD at mature operation, 2035) Value
Direct factory employment 1,330 FTE
Annual production 2,800 systems/year (KM1 ISR + KM2 commercial in parallel)
Annual production capacity 176 MW/year
Cumulative installed capacity 2027-2038 ~1,136 MW
Cumulative greenhouse gas avoidance 2027-2038 ~3.5 Mt CO2e
Cost efficiency (CAPEX-based) ~EUR 10/tCO2
Total factory CAPEX EUR 35 M (60 % EU IF, 40 % equity + partners)
Factory opening Q3 2029

Employment beyond a single factory: 1,330 FTE covers only one KM1+KM2 factory. The ISR market alone requires more production lines than a single factory can deliver against known demand; equivalently, additional factories or expansions are anticipated for commercial KM2 volume as the market matures. Employment in the supplier chain comes in addition.

Norwegian supplier position — critical components:

The FJORD factory sources from a European supplier network where Norway has historical and ongoing leadership in several categories:

Component Volume 2035 Norwegian supplier position
Winch (20-100 kW) 2,800 units/year The Norwegian marine winch industry has a historical leadership position in offshore, fisheries and aquaculture, and is a priority supplier base for the FJORD factory
Composite structures (airframe) ~35 t prepreg/year Eker Group (composite MoU under preparation), High Performance Composite AS (current Norwegian supplier)
Tether (UHMWPE rope) tens of km/year of aerospace grade The Norwegian fibre-rope industry has a strong position in offshore and marine applications
Wire harness, battery, sensors 2,800 sets/year Norwegian/European suppliers preferred; standardised industrial electronics
Power electronics and frequency converters 2,800 sets/year Norwegian industry has a strong position (the ABB heritage, suppliers in the electrical-engineering ecosystem)

Connection NAWEP - FJORD: NAWEP delivers the technical and regulatory maturation that is a precondition for the FJORD investment. Industrial and institutional partners will not commit to a EUR 35M factory without having seen the technology operate under a Norwegian licensing regime. Refusal or delay of NAWEP therefore weakens not only the local project, but also the basis for FJORD being built in Norway rather than in another European country.

19.4.6 AWE as disruptive technology in the global energy market

The physical properties of AWE technology open for substantial expansion of globally available renewable resource:

Wind resource at 200-400 m operating altitude: - Wind speeds are typically 2-3 times higher than at conventional hub height (80-150 m) - Power potential grows cubically with wind speed — operating altitude provides substantially higher energy density and a more consistent capacity factor - Less variability than at ground level gives better grid interaction and reduced need for balancing reserves

Geographical reach: - Conventional wind power is economically viable in limited parts of the global land area (mainly coastal or high-mountain belts with sufficient wind speed at hub height) - AWE systems at 300-400 m can exploit wind resource in a substantially larger share of the global area — including low-wind regions at the surface, islands with weak grids, topographically difficult areas and areas with land-use conflicts against tall towers - This expands the addressable market segment significantly compared with conventional wind power

Consequence for the energy transition: - AWE enables local power production in areas where conventional wind power is not considered relevant, without conflicts associated with tall permanent towers, access roads or concrete foundations - Global applications: replace fossil baseload sources in regions with weak grids (developing markets), island states, Arctic operations, forward military bases, industrial off-grid activity - Complementarity with hydropower and solar (cf. fig. 2.4.1) strengthens supply security in Southern Norway in particular

NAWEP's role in the global context: As the first licensed AWE plant in Norway under the revised BSL A 7-2 regime (2024), NAWEP is the demonstration that opens the Norwegian and European market for a technology with disruptive potential in the global energy market. Refusal weakens Norwegian industrial position in an emerging sector where technological, regulatory and market leadership are being shaped now.

19.4.7 Net assessment

Quantified against the zero alternative, NAWEP delivers +4.2 GWh/year of renewable energy, +630 t CO2e/year of climate savings, and 76-85 MNOK in direct regional investment against a permanent land use of 0.05 hectares and impacts which, after mitigation measures, lie below the T-1442/2021 limit value for noise and without documented unacceptable consequences for birds or biodiversity. In addition, EUR 3.35M+ in EU funding is secured for NAWEP itself, and the project lays the foundation for the EUR 35M FJORD factory investment (1,330 FTE at mature operation) which, with national location, will build a Norwegian supplier and competence ecosystem in a sector with disruptive global potential.

The relationship between quantified benefits and drawbacks, combined with 100 % reversibility at project end and a phased approach that allows iterative assessment, indicates that NAWEP overall provides a substantial net positive societal and environmental benefit compared with the zero alternative — both directly in the pilot phase and indirectly through industrial and technological scale-up.


20. MITIGATION MEASURES AND COMMITMENTS

This chapter brings together all mitigation measures and commitments across the topical chapters. For fuller descriptions, reference is made to the respective chapters.

20.1 Measures matrix per topic

20.1.1 Noise (cf. section 11.7)

Measure Description Period Effect
KM2 design optimisation TE design, BL tripping, helical strake, tether design, wing profile 2026 (design) → operation -10 to -15 dB Lw_kite
Per-kite buffer 430 m Geo-fence around the nearest dwelling Operation Ensures Lp_single ≤ 45 dB
Night shutdown M, N, O Stations M, N and O are not operated 23:00-07:00 Continuous operation -3 to -5 dB during night period
Selective shutdown of nearest station At critical wind direction towards dwelling Dynamic operation -1 to -3 dB at specific hours
Operational optimisation Speed, altitude, AoA, direction, line length Continuous -2 to -10 dB
Neighbour forum with Nordhassel/Råstad Direct dialogue in case of perceived burden Continuous (≥ annual meeting) Adjustment as needed
Acoustic measurement programme Source noise + immission at settlements Within 6/12 months of commissioning Verification Lden ≤ 45 dB

20.1.2 Biodiversity and birds (cf. chapters 8 and 9)

Measure Description Period Effect
Phased ramp-up From 1 to 15 systems over 3 years 2026-2028 Gradual knowledge building
Daytime flying only in start-up phase Avoids night-time migration activity 2026 Reduces nocturnal collision risk
Limited night flying under observation Only when detection equipment is operational 2027 Verified night operation
Operational shutdown in busiest migration period Spring and autumn migration 2028+ Eliminates collision risk in high-risk periods
Bird monitoring (field campaigns) Seasonal campaigns spring, summer, autumn 2026-2031 Factual basis for evaluation
Selective operational shutdown M, N, O Stations closest to Slevdalsvannet at sensitive wind direction Operation Reduces impact on water birds
Continuous collision monitoring AI-based cameras + manual search Continuous operation Documentation of actual impact
Annual evaluations Acceptable impact must be documented before continued operation 2029-2031 Adaptive management

20.1.3 Landscape and visual impacts (cf. chapter 10)

Measure Description Period Effect
Low ground stations (~3 m height) Little visible from ground level Operation Limited visual impact
Reversibility Steel frames, no concrete foundation Decommissioning Full restoration possible
Operation only at production wind Kites not visible without wind Operation Less exposure than conventional wind power
No light marking beyond BSL E 2-1 minimum Reduces light pollution at night Operation Protects dark sky

20.1.4 Outdoor recreation and outfield use (cf. chapter 13)

Measure Description Period Effect
Operation within the airport's fence No new land interventions in outfield Operation No new barriers for outdoor recreation
Information boards At hiking routes with view of the plant Start-up Information for hikers
No impact on Lista beaches Operation entirely within airport Operation Protects central recreation area

20.1.5 Public health and living environment (cf. chapter 15)

Measure Description Period Effect
Noise measures (cf. 20.1.1) Lden ≤ 45 dB(A) at facade Operation T-1442/2021 observed
Distance to settlements Minimum 765 m from the nearest dwelling By design Sufficient physical distance
Ekom measures (cf. chapter 15) In case of measured interference, modification or shutdown Operation, on warning Protects mobile/radio/TV
Water and ground measures (cf. chapter 15) No permanent pollution, oil spill response procedure Operation Protects groundwater
Neighbour forum Open dialogue with affected neighbours Continuous Holistic neighbourhood management

20.1.6 Cultural heritage and cultural environment (cf. chapter 14)

Measure Description Period Effect
No physical interventions in protected cultural heritage Operation only within the airport fence Operation Preserves all SEFRAK/RA objects
Visual consideration zone Nordberg fort No light marking or other measures that disturb the fort Operation Protects cultural environment
Cultural heritage professional follow-up In the event of any unforeseen finds during installation Installation Cultural Heritage Act § 8

20.1.7 Co-use and coordination (cf. chapter 16)

Measure Description Period Effect
Agreement with Lista Lufthavn AS Coordination of air traffic and ground operations Continuous Secures flight operations
Agreement with the Armed Forces (cf. section 17.4) Coordination of airspace and exercises Continuous Defence interests safeguarded
Dialogue with Glitre Nett Grid connection and operational coordination Continuous Stable grid operation
Emergency preparedness plan in critical situations Shutdown procedures in case of acute incidents Operation Rapid response

20.1.8 Natural hazards and safety (cf. chapter 17)

Measure Description Period Effect
Tether tethering and controlled landing 4-layer containment architecture Operation Limits debris to controlled ground area
Geo-fence Active monitoring of kite position Operation Prevents flying outside approved area
BSL E 2-1 light marking Obstruction marking in accordance with regulation Operation Ensures aviation safety
BVLOS approval (NOR-OAT-000294/000) SAIL II level approval from CAA-N, valid until 16.10.2027 Operation Full regulatory basis
Emergency preparedness procedures In case of emergency, immediate shutdown Operation Personnel safety

20.2 Commitments

Kitemill AS commits to the following, as binding license conditions:

20.2.1 General commitments

  1. To carry out all mitigation measures listed in 20.1 in accordance with the described plan
  2. To maintain close dialogue with NVE, the County Governor and affected neighbours throughout the license period
  3. To carry out annual evaluations and report to NVE
  4. To adjust or reverse the plan in case of unacceptable consequences
  5. To contribute to increased knowledge of AWE technology through open reporting

20.2.2 Noise commitments

  1. Binding threshold value: Lden 45 dB(A) at the facade of the nearest noise-sensitive built environment shall not be exceeded, cf. T-1442/2021
  2. Night shutdown: Stations M, N and O are not operated during the night period 23:00-07:00
  3. Geo-fence buffer: No kite shall fly closer than 430 m from a dwelling
  4. Measurement programme: Source noise and immission measurement in accordance with IEC 61400-11 within 6 months of commissioning; ISO 9613-2 propagation calculation within 12 months
  5. Iterative adjustment: In case of measured exceedance, further measures are implemented within 6 months
  6. Neighbour forum: Established with at least annual meetings; more at start-up

20.2.3 Biodiversity commitments

  1. To carry out bird monitoring through field campaigns in relevant seasons (spring, summer, autumn)
  2. To share all collected data with the County Governor and NVE
  3. To implement operational shutdown in the busiest migration periods
  4. To contribute to increased knowledge of birds and migratory birds at Lista, including spring migration and AWE-specific bird behaviour

20.2.4 Operational commitments

  1. Operation in accordance with BSL E 2-1, BSL A 7-2 (regulation 2024-11-01-2777 on unmanned aviation, Norwegian regulation on unmanned aviation, implementing EU 2019/947), SORA 2.0/2.5, and BVLOS approval NOR-OAT-000294/000 (valid until 16.10.2027)
  2. Emergency preparedness procedures documented in the Operations Manual
  3. Tether tethering and controlled landing on loss of control
  4. Closed geo-fence in the control system

20.2.5 Reversibility

  1. All ground stations can be dismantled without lasting traces
  2. No permanent concrete foundations
  3. Restoration of area at the end of the license or if the project is terminated earlier

20.3 Measurement programme and reporting

Measurement programme Frequency Recipient
Acoustic source noise measurement (KM2) Within 6 months of commissioning NVE, public publication
Acoustic immission measurement Continuous 1 week/quarter year 1; thereafter on warning NVE, neighbour forum
Bird monitoring Seasonal campaigns spring/summer/autumn County Governor, NVE
Collision monitoring Continuous (AI camera + manual) County Governor, NVE
Operating and production data Continuous logging NVE annual report
Neighbourhood feedback As needed, formally registered Neighbour forum, NVE annual report
NAWEP annual report Annually NVE

21. APPENDICES

All appendices are collected in the subfolder Vedlegg/ with consistent naming (Vedlegg NN - <title>.<ext>). Filenames remain in Norwegian as they refer to the actual files on disk; descriptions are translated.

Documents

No Appendix File name (in Vedlegg/) Description
01 NNI Report 520 - Bird study Lista 2018 Vedlegg 01 - NNI-rapport 520 - Fuglestudie Lista 2018.pdf Ornithological survey Lista 2018. Also available online
02 Bouman, N. (2023) - Acoustic field measurements Vedlegg 02 - Bouman 2023 - Akustiske feltmaalinger KM1.pdf MSc thesis TU Delft, field measurements of the KM1 system at Lista Airport on 27.03.2023. Also available online
03 Glitre Nett maturity assessment Vedlegg 03 - Glitre Nett Modenhetsvurdering 21.11.2024.pdf Grid connection assessment, ref. IN-00002114, dated 21.11.2024
04 CAA-N - VLOS operating permit KM1 Vedlegg 04 - VLOS-driftstillatelse KM1 (22-02391-46).pdf Updated operating permit dated 20.01.2025
05 CAA-N - BVLOS operating permit KM1 Vedlegg 05 - BVLOS-driftstillatelse KM1 (NOR-OAT-000294-000).pdf BVLOS approval, SAIL II, valid 16.10.2025 - 16.10.2027
06 Farsund municipality - Case extract 25/00659-5 Vedlegg 06 - Saksutskrift Farsund kommune 17.06.2025.pdf Dispensation decision with consultation statements and developer's comments
07 Environmental Impact Assessment NAWEP Vedlegg 07 - Konsekvensutredning NAWEP.pdf Complete environmental impact assessment pursuant to the EIA Regulations chapter 5
08 Risk assessment NAWEP Vedlegg 08 - Risikovurdering NAWEP.pdf Risk assessment pursuant to NVE point 3 (prepared by CTO Marius Dyrset)
09 Tender from external contractor (Grunnlink) for civil works Vedlegg 09 - Tilbud grunnarbeid NAWEP (UNNTATT OFFENTLIGHET).pdf Costed tender from Grunnlink for civil works, dated 27.08.2025. Comprises offer letter, application, cost breakdown and progress plan (6 pages). Exempt from public access pursuant to the Public Access Act § 13 (trade secrets)

Maps and shapefiles

No Appendix File name (in Vedlegg/) Description
10 Regional overview map Vedlegg 10 - Regionalt oversiktskart.jpg Regional context, project area location
11 Local overview map Vedlegg 11 - Lokalt oversiktskart.jpg Local environment with population centres and topography
12 Station locations Vedlegg 12 - Stasjonsplasseringer A-O.png Map with stations A-O and grid
13 Infrastructure map Vedlegg 13 - Bygninger og veier.jpg Buildings, roads and built environment
14 Protected areas map Vedlegg 14 - Verneomraader.jpg All protected areas in the region
15 Protected areas and species hotspots Vedlegg 15 - Verneomraader og artshotspots.jpg Protected areas with species records
16 Slevdalsvannet and Nesheimsvatnet Vedlegg 16 - Slevdalsvannet og Nesheimvatnet.jpg Nearest nature reserves
17 Grid drawings (Shapefile) Vedlegg 17 - Grid-tegninger.zip Shapefile bundle (.shp/.shx/.dbf/.prj/.cpg) in EPSG:25833 (UTM33N/EUREF89) for NVE Atlas publication. Contains grid layout with station locations (48 features across points, lines and polygons). KML source: GRIDtegninger21.02.2025v1
18 Operating area (Shapefile) Vedlegg 18 - Operasjonsomraade.zip Shapefile bundle in EPSG:25833 with operating limits (17 features). KML source: Operasjonsområdet tegninger 6.11.2024
19 Danger area airspace (Shapefile) Vedlegg 19 - Fareomraade luftrom END257.zip Shapefile bundle in EPSG:25833 with danger area END257 (1 polygon). KML source: 250225_DangerArea
20 Nature protection areas Nesheimsvatnet (Shapefile) Vedlegg 20 - Naturvernomraader Nesheimsvannet.zip Shapefile bundle in EPSG:25833 (1 polygon)
21 Nature protection areas Slevdalsvannet (Shapefile) Vedlegg 21 - Naturvernomraader Slevdalsvannet.zip Shapefile bundle in EPSG:25833 (1 polygon)

Visualisations

No Appendix File name (in Vedlegg/) Description
22 3D view stations south Vedlegg 22 - 3D-visning stasjoner sor.png Station locations F, H, K, M, N, L (oblique perspective)
23 3D view all stations Vedlegg 23 - 3D-visning alle stasjoner.png All 15 stations with operating pattern (oblique perspective)
24 Operating circles from above (3D rendering, technical) Vedlegg 24 - Operasjonssirkler ovenfra (3D-rendering).png Technical overview map in plan - not a publicly accessible viewpoint
25 Operating pattern alternative angle (3D rendering, technical) Vedlegg 25 - Operasjonsmonster alternativ vinkel.png Technical overview map - not a publicly accessible viewpoint
26 Ground level - circular motions (Ore krysset) Vedlegg 26 - Bakkenivaa sirkelbevegelser (Ore krysset).png Visual impact from a publicly accessible viewpoint (Ore krysset)
27 Ground level - all 15 kites (Ore krysset) Vedlegg 27 - Bakkenivaa alle 15 kiter (Ore krysset).png 15 kites in operation, seen from Ore krysset
28 Actual photo of KM1 prototype at Lista Vedlegg 28 - Faktisk foto KM1-prototype Lista.jpg KM1 system in operation at Lista (prototype location differs from the NAWEP stations)

New maps (NVE revision 2026)

No Appendix File name (in Vedlegg/) Description
29 Noise zone map Vedlegg 29 - Stoysonekart NAWEP.{png,pdf} Calculated Lden 35-55 dB(A) contours per station and aggregated (NVE point 4.7)
30 Population density Vedlegg 30 - Befolkningstetthet NAWEP.{png,pdf} Estimated population density around NAWEP (NVE point 4.7)
31 SORA population categories Vedlegg 31 - SORA befolkningskategorier.{png,pdf} Classification pursuant to SORA 2.0 (Controlled / Sparsely / Populated)
32 Distances to roads and buildings Vedlegg 32 - Avstander NAWEP.{png,pdf} + Vedlegg 32 - Avstander stasjoner.csv Distances from each ground station to County road 43, Flyplassveien, buildings and dwellings (NVE point 4.3f)

Other documents

No Appendix File name (in Vedlegg/) Description
33 Contact persons and stakeholders Vedlegg 33 - Kontaktpersoner og interessenter (UNNTATT OFFENTLIGHET).pdf Contact information for the municipality (Farsund), grid company (Glitre Nett), professional staff (NNI/Håland) and applicant (Kitemill). Exempt from public access pursuant to the Public Access Act § 13 (personal data)
34 CAA-N consultation response (Holte 08.05.2025) Vedlegg 34 - Hoeringssvar Luftfartstilsynet (August Holte 08.05.2025).pdf CAA-N's consultation response (ref. 25/18542-2) to Farsund municipality regarding temporary dispensation for the NAWEP demonstration plant, signed by Section Head August Holte. Exempt from public access — publication not agreed with CAA-N. The substantive content (positive statement, reference to BSL E 2-1 and danger area END257) is publicly available via Farsund municipality's case archive (case 25/00659-5, cf. Appendix 06) and through AIC-N 15/23 13 OCT

Kitemill AS Flyplassveien 40, 4560 Vanse Org. no.: 992 943 718

Farsund, February 2026

Chapter 1 of 22
Executive Summary
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